pollution exclusion clause (Washington) · Go Syfert
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pollution exclusion clause in Washington

12 Washington opinions name it 2 courts 1983–2016 0 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Queen City Farms, Inc. v. Central Nat'l Ins. Co. of Omahagreen
wash · 1995 · cited in 5 Washington opinions naming this issue, 1998–2016
2 sentences

2016The Supreme Court in Queen City Farms held that the term “sudden and accidental” in the exception to the pollution exclusion clause means “unexpected and unintended.” 126 Wn.2d at 86-87 .

1998We held that under the pollution exclusion clause, damage is not covered if it is “expected or intended.” Queen City Farms, 126 Wn.2d at 87 .

25
Madison Construction Co. v. Harleysville Mutual Insurancegreen
pa · 1999 · cited in 2 Washington opinions naming this issue, 2005–2005
2 sentences

2005Co., 735 A.2d at 108 (“If the pollution exclusion clause, by its express terms, does not require that a discharge or dispersal be ‘into the environment’ or ‘into the atmosphere,’ then the court is not at liberty to insert such a requirement in order to effect what it considers to be the true or correct meaning of the clause.”). ¶36 Therefore, we conclude that the Kent Farms discussion of traditional environmental harms is limited by the facts of that case.

2005Co., 735 A.2d at 108 ("If the pollution exclusion clause, by its express terms, does not require that a discharge or dispersal be `into the environment' or `into the atmosphere,' then the court is not at liberty to insert such a requirement in order to effect what it considers to be the true or correct meaning of the clause."). ¶ 36 Therefore, we conclude that the Kent Farms discussion of traditional environmental harms is limited by the facts of that case.

22
Cook v. Evansongreen
washctapp · 1996 · cited in 2 Washington opinions naming this issue, 2005–2005
2 sentences

2005See id. at 152-54 . ¶17 The Cook appellants argued that the pollution exclusion should be interpreted to cover only traditional environmental harms, but not injuries arising from normal business operations.

2005Id. at 156 .

22
City of Bremerton v. Harbor Ins. Co.green
washctapp · 1998 · cited in 1 Washington opinions naming this issue, 2005–2005
1 sentence

2005See id. at 24, 963 P.2d 194 . ¶ 20 Then, in 2000, this court accepted review of an absolute pollution exclusion case.

11
Gruenwald v. Advanced Computer Applications, Inc.green
pasuperct · 1999 · cited in 1 Washington opinions naming this issue, 2000–2000
1 sentence

2000They are not at issue in this appeal. [13] In Pennsylvania, "To prove fraud, a plaintiff must demonstrate: (1) a representation; (2) which is material to the transaction at hand; (3) made falsely, with knowledge of its falsity or recklessness as to whether it is true or false; (4) with the intent of misleading another into relying on it; (5) justifiable reliance on the misrepresentation; and (6) the resulting injury was proximately caused by the reliance." Gruenwald v. Advanced Computer Applications, Inc., 730 A.2d 1004, 1014 (Pa.Super.1999).

11
Island Associates, Inc. v. Eric Group, Inc.green
pawd · 1995 · cited in 1 Washington opinions naming this issue, 1996–1996
1 sentence

1996In Island Associates, Inc. v. Eric Group, Inc., the court found the same clause ambiguous when applied to an injury from cleaning compound fumes confined to a small area within the worksite. 894 F. Supp. 200, 203 (W.D.

11
American Star Insurance v. Gricegreen
wash · 1993 · cited in 1 Washington opinions naming this issue, 1996–1996
1 sentence

1996See American Star, 121 Wn.2d at 875 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Niagara County v. Utica Mutual Insurance green
nysupct · 1980
2 sentences

1992The court in Niagara concluded that "the pollution exclusion was solely meant to deprive active polluters of coverage." Niagara, 103 Misc. 2d at 818 , 427 N.Y.S.2d at 174 .

1992The court in Niagara concluded that "the pollution exclusion was solely meant to deprive active polluters of coverage." Niagara, 103 Misc. 2d at 818 , 427 N.Y.S.2d at 174 .

21983–1992
Kent Farms, Inc. v. Zurich Ins. Co. green
wash · 2000
1 sentence

2005Id. (citing Cont'l Cas.

12005–2005
Kent Farms, Inc. v. Zurich Insurance green
wash · 2000
1 sentence

2005Id. (citing Cont’l Cas.

12005–2005
Olympic Steamship Co., Inc. v. Centennial Ins. Co. green
wash · 1991
2 sentences

2000Pursuant to Olympic Steamship Co. v. Centennial Insurance Co., 117 Wn.2d 37, 52 , 811 P.2d 673 (1991), we grant respondent’s request for reasonable attorney fees.

2000Pursuant to Olympic Steamship Co. v. Centennial Insurance Co., 117 Wn.2d 37, 52 , 811 P.2d 673 (1991), we grant respondent’s request for reasonable attorney fees.

12000–2000
West American Insurance Co. v. Tufco Flooring East, Inc green
ncctapp · 1991
1 sentence

1996The appellants also cite West American Insurance v. Tufco Flooring East, 104 N.C.

11996–1996
Lumbermens Mutual Casualty Co. v. Belleville Industries, Inc. green
mass · 1990
2 sentences

1995Co. v. Belleville Indus., Inc., 407 Mass. 675, 680 , 555 N.E.2d 568 (1990) (concluding the "better reasoned, and particularly the more recent, judicial interpretations of the pollution exclusion clause" conclude it is clear and unambiguous). [9] *122 In retrospect, the prediction of consensus regarding the pollution exclusion may have been optimistic.

1995Co. v. Belleville Indus., Inc., 407 Mass. 675, 680 , 555 N.E.2d 568 (1990) (concluding the "better reasoned, and particularly the more recent, judicial interpretations of the pollution exclusion clause" conclude it is clear and unambiguous). [9] *122 In retrospect, the prediction of consensus regarding the pollution exclusion may have been optimistic.

11995–1995
JACKSON TP. ETC. v. Hartford Acc. & Indemn. Co. green
njsuperctappdiv · 1982
1 sentence

1992Super. 156 , 451 A.2d 990 (1982), cited in Van's Westlake, at 712, in a subsequent writing: It is too simplistic a solution to say that the pollution exclusion clause is ambiguous and, therefore, inapplicable to the typical groundwater pollution case.

11992–1992
Technicon Electronics Corp. v. American Home Assurance Co. green
ny · 1989
2 sentences

1992Technicon, 74 N.Y.2d at 75 .

1992(Italics ours.) Technicon, 74 N.Y.2d at 75 .

11992–1992

Statutes the citing opinions construe

USC § 42u.s.c.9601-9675 (5) USC § 42u.s.c.9601 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NJ 29 (1982–2022) WI 25 (1987–2018) NY 22 (1980–2024) MI 15 (1989–2015) MA 15 (1985–2011) IL 14 (1984–2026) CA 12 (1993–2025) WA 12 (1983–2016) MN 12 (1988–2013) CT 11 (1995–2017) PA 11 (1997–2006) LA 10 (1991–2021) CO 10 (1990–2013) TX 7 (1993–2015) MD 6 (1994–2017) OH 6 (1984–2009) OR 5 (1985–1999) FL 5 (1994–1998) AL 4 (1997–2007) GA 4 (1995–2016) NE 3 (2001–2020) MO 3 (1999–2013) NM 3 (2011–2012) SD 3 (2000–2023) IN 3 (1997–2026) AR 3 (1993–2012) DE 2 (1988–1995) OK 2 (1995–2022) MT 2 (2005–2008) RI 2 (2000–2023) KS 2 (1993–1995) NH 2 (1996–2015) NC 2 (1986–2000) AZ 2 (2000–2019) KY 2 (1996–2011) SC 2 (1991–1993) WV 2 (1992–1994)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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