Hunton Insurance Recovery Blog

Whether a loss counts as one “occurrence” or many can determine whether meaningful coverage is available. In J.M. Smucker Company v. Ace American Insurance Company, the Sixth Circuit held that thousands of claims tied to alleged salmonella contamination in peanut butter arose from a single occurrence—not hundreds of separate occurrences grouped by production lot. For manufacturers and other policyholders facing recall or mass-claim exposure, the decision is a useful reminder that courts applying a cause-based analysis should look to the common source of the alleged harm, not the number of claimants.