Hunton Andrews Kurth Secures Unanimous Reversal for Lionbridge Technologies, LLC in First Circuit Court of Appeals

On November 21, 2022, the Insurance Recovery and Issues and Appeals practices of Hunton Andrews Kurth LLP secured a significant victory for firm client Lionbridge Technologies, LLC, in the U.S. Court of Appeals for the First Circuit.  The panel unanimously reversed the trial court’s summary judgment decision finding that Lionbridge’s insurer, Valley Forge Insurance Company, had no duty to defend Lionbridge under a commercial general liability insurance policy in connection with a lawsuit involving Lionbridge in the U.S. District Court for the Southern District of New York.  

The First Circuit decision reaffirmed liability insurers’ broad duty to defend policyholders against actions involving claims that are potentially covered, which the trial court had called into question.  Indeed, the First Circuit held that a single paragraph in the underlying complaint “roughly sketched” a claim covered by Lionbridge’s policy, even though the complaint did not include a specific cause of action for the covered claim, which was sufficient to trigger Valley Forge’s duty to defend.  The First Circuit also narrowly interpreted multiple exclusions to coverage and determined none applied to relieve Valley Forge of its defense obligation, reversing the trial court’s determination otherwise.  The decision represents a victory not only for Lionbridge, but also for all Massachusetts policyholders. 

The cross-practice effort was led by partner Walter Andrews, counsel Nick Stellakis, and associate Kevin Small.  Associates Janine Hanrahan, Casey Coffey and Cameron Davis provided instrumental assistance.