Hunton Insurance Recovery Blog

The Fourth Circuit in APAC-Atlantic, Inc. v. Owners Insurance Co., No. 24-1969, 2026 WL 458402 (4th Cir. Feb. 18, 2026) recently endorsed broad coverage for additional insureds, interpreting “arising out of” broadly under North Carolina law to extend coverage to a repaving company under its subcontractor’s liability insurance policy. The court held that an additional insured’s liability “arising out of” a named insured’s work in an additional-insured endorsement means liability “relating to” or “causally connected to” the named insured’s operations, rather than liability defined more narrowly as “caused by” or “the fault of” the named insured.

In a recent article published by the American Bar Association, Hunton attorneys Geoffrey Fehling and Brittany De Vries analyze this recent Fourth Circuit decision in APAC-Atlantic. They review the APAC-Atlantic decision in the context of how ISO additional-insured endorsement language has changed over time, how courts have interpreted this varying endorsement language in determining additional-insured coverage, and what this means for construction and other trade industries looking to max out on potential risk allocation and indemnification when procuring insurance or engaging in work. The full article can be found here.