Urena v. Travelers Casualty and Surety Co. of America

Summary

The First Circuit affirmed the district court's judgment on the pleadings in favor of Travelers Casualty and Surety Company of America, holding that the insurer's policy did not cover losses from a pregnancy-discrimination judgment against the insured employer. The court held that the policy's Related Claims provision in the Liability Coverage Terms and Conditions (LCTC) applies to all claims, including Employment Claims under the Employment Practices Liability (EPL) endorsement, so the January 2021 suit was deemed first made when the 2019 administrative complaint was made — before the EPL policy period began. The court rejected the administrators' arguments that the EPL endorsement superseded the LCTC's Related Claims provision, finding no conflict between the provisions.