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

11 Pennsylvania opinions name it 4 courts 1997–2006 0 in the last five years

The cases below were cited by Pennsylvania 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 (10)

CaseFollowedCited
Madison Construction Co. v. Harleysville Mutual Insurancegreen
pa · 1999 · cited in 6 Pennsylvania opinions naming this issue, 1999–2006
2 sentences

2006In Madison Construction Company v. The Harleysville Mutual Insurance Company, 557 Pa. 595 , 735 A.2d 100 (1999), the issue was whether a pollution exclusion clause in a policy of commercial general liability insurance relieved Harleysville of its duty to defend in a personal injury action.

2006In Madison Construction Company v. The Harleysville Mutual Insurance Company, 557 Pa. 595 , 735 A.2d 100 (1999), the issue was whether a pollution exclusion clause in a policy of commercial general liability insurance relieved Harleysville of its duty to defend in a personal injury action.

36
Lower Paxon Township v. United States Fidelity & Guaranty Co.green
pa · 1989 · cited in 2 Pennsylvania opinions naming this issue, 1997–1999
2 sentences

1999In Lower Paxton, our Court interpreted the phrase "sudden and accidental" in a pollution exclusion clause identical to that at issue in this case and determined that, because that clause was unambiguous on its face, the Court would not consider extrinsic evidence, such as the historical context in which that clause was approved by the Pennsylvania Insurance Department. 557 A.2d at 402 n. 5. ¶ 12 Sunbeam argues that, even if the phrase "sudden and accidental" is patently unambiguous, as the trial court determined, extrinsic evidence nevertheless should have been considered to determine if any l

1999Sunbeam bases its arguments on certain principles of contract interpretation and the decisions of courts in other jurisdictions, which have interpreted the same pollution exclusion clause as that at issue in this case and have interpreted "sudden" to mean only "unexpected." ¶ 23 Rejecting Sunbeam's definition of "sudden," the trial court in this case was bound by this Court's decision in Lower Paxton, in which we determined that the natural, plain, and ordinary meaning of the word "sudden" included a "temporal element that joins together conceptually the immediate and the unexpected." 557 A.2d

22
Lititz Mutual Insurance v. Steelygreen
pasuperct · 1999 · cited in 3 Pennsylvania opinions naming this issue, 2001–2001
2 sentences

2001Co. v. *13 Steely, 746 A.2d 607 (Pa.Super.1999). [3] In Lititz, our Court found that the pollution exclusion clause is unambiguous and that lead-based paint is a pollutant.

2001Co. v. Steely, 746 A.2d 607 (Pa.Super.1999). 3 In Lititz, our Court found that the pollution exclusion clause is unambiguous and that lead-based paint is a pollutant.

13
Lititz Mutual Insurance v. Steelygreen
pa · 2001 · cited in 2 Pennsylvania opinions naming this issue, 2002–2002
2 sentences

2002See id. ¶ 13 We conclude accordingly, that Northside’s claim for defense and indemnity does not fall within the scope of the pollution exclusion clause in Northwestern’s policy.

2002The supreme court in Lititz agreed with this court that "the definition of pollutant’ in the pollution exclusion clause unambiguously encompasses lead-based paint.” Lititz, supra at -, 785 A.2d at 980 .

12
Washington v. Baxtergreen
pa · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2001–2001
2 sentences

2001Washington v. Baxter, 553 Pa. 434, 441 , 719 A.2d 733, 737 (1998) (citations and quotation marks omitted). ¶ 6 HRIE presents the following issues for our review: (1) whether lead-based paint is a pollutant within the meaning of the pollution exclusion clause; and (2) whether lead-based paint separating from a painted surface falls within the pollution exclusion clause meaning of discharge, dispersal, seepage, migration, release or escape of pollutants.

2001Washington v. Baxter, 553 Pa. 434, 441 , 719 A.2d 733, 737 (1998) (citations and quotation marks omitted). ¶ 6 HRIE presents the following issues for our review: (1) whether lead-based paint is a pollutant within the meaning of the pollution exclusion clause; and (2) whether lead-based paint separating from a painted surface falls within the pollution exclusion clause meaning of discharge, dispersal, seepage, migration, release or escape of pollutants.

11
Byrd Ex Rel. Byrd v. Blumenreichgreen
njsuperctappdiv · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2001–2001
2 sentences

2001See Byrd v. Blumenreich, 317 N.J.Super. 496 , 722 A.2d 598, 600 (1999) (collecting cases); Danbury Ins.

2001See Byrd v. Blumenreich, 317 N.J.Super. 496 , 722 A.2d 598, 600 (1999) (collecting cases); Danbury Ins.

11
Hertzberg v. Zoning Board of Adjustmentgreen
pa · 1998 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999
1 sentence

1999See Hertzberg v. Zoning Board of Adjustment of the City of Pittsburgh, 554 Pa. 249 , 256 n. 6, 721 A.2d 43 , 46 n. 6 (1998) (finding that concept of standing is that person who is not adversely affected in any way by the matter he seeks to challenge is not `aggrieved' thereby and has no standing to obtain a judicial resolution of his challenge). [3] We note that the trial court did not have the benefit of our Supreme Court's discussion and analysis of the issues in Madison. [4] We note that the question before us is whether the pollution exclusion clause, contained in the insurance contract en

11
Milne v. Crossettgreen
pa · 1998 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999
1 sentence

1999See Hertzberg v. Zoning Board of Adjustment of the City of Pittsburgh, 554 Pa. 249 , 256 n. 6, 721 A.2d 43 , 46 n. 6 (1998) (finding that concept of standing is that person who is not adversely affected in any way by the matter he seeks to challenge is not `aggrieved' thereby and has no standing to obtain a judicial resolution of his challenge). [3] We note that the trial court did not have the benefit of our Supreme Court's discussion and analysis of the issues in Madison. [4] We note that the question before us is whether the pollution exclusion clause, contained in the insurance contract en

11
West American Insurance Co. v. Tufco Flooring East, Incgreen
ncctapp · 1991 · cited in 1 Pennsylvania opinions naming this issue, 1999–1999
2 sentences

1999Id. at 324 , 409 S.E.2d at 699 (footnote excluded).

1999Id. at 324 , 409 S.E.2d at 699 (footnote excluded).

11
O'Brien Energy Systems, Inc. v. AMERICAN EMPLOYERS'INS. CO.green
pasuperct · 1993 · cited in 1 Pennsylvania opinions naming this issue, 1997–1997
2 sentences

1997Plaintiffs recognize that at this time they cannot recover in this court by arguing that the plain and ordinary meaning of the words in the pollution exclusion clause permits an interpretation which excludes coverage only in cases of intentional pollution — i.e., where the property damage was either expected or intended by the insured. 2 The Pennsylvania Superior Court has consistently ruled that this standard pollution exclusion bars coverage for “any unintentional release or dispersal of pollution that occurs gradually over time”; there is coverage only where a discharge is “both sudden, mea

1997Plaintiffs recognize that at this time they cannot recover in this court by arguing that the plain and ordinary meaning of the words in the pollution exclusion clause permits an interpretation which excludes coverage only in cases of intentional pollution — i.e., where the property damage was either expected or intended by the insured. 2 The Pennsylvania Superior Court has consistently ruled that this standard pollution exclusion bars coverage for “any unintentional release or dispersal of pollution that occurs gradually over time”; there is coverage only where a discharge is “both sudden, mea

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
Riccio v. American Republic Insurance green
pa · 1997
2 sentences

1999Id. ¶ 14 Recently, the Pennsylvania Supreme Court, interpreting certain words in a pollution exclusion clause similar to that involved in this case, emphasized that the “polestar” of insurance contract interpretation “is the language of the ... policy.” Madison Constr.

1999Id. ¶ 14 Recently, the Pennsylvania Supreme Court, interpreting certain words in a pollution exclusion clause similar to that involved in this case, emphasized that the "polestar" of insurance contract interpretation "is the language of the ... policy." Madison Constr.

11999–1999
Gene & Harvey Builders, Inc. v. Pennsylvania Manufacturers' Ass'n green
pa · 1986
2 sentences

1999The court’s only aim, as noted earlier, must be “to ascertain the intent of the parties as manifested by the language of the written instrument....” 7 Gene & Harvey, 512 Pa. at 426 , 517 A.2d at 913 (quoting Standard Venetian Blind, 503 Pa. at 305 , 469 A.2d at 566 ) (emphasis added).

1999The court’s only aim, as noted earlier, must be “to ascertain the intent of the parties as manifested by the language of the written instrument....” 7 Gene & Harvey, 512 Pa. at 426 , 517 A.2d at 913 (quoting Standard Venetian Blind, 503 Pa. at 305 , 469 A.2d at 566 ) (emphasis added).

11999–1999
Madison Construction Co. v. Harleysville Mutual Insurance green
pasuperct · 1996
2 sentences

1999We conclude, as did the en banc Superior Court, 451 Pa.Super. 136 , 678 A.2d 802 , that the pollution exclusion clause operates to bar coverage in the present case, and therefore affirm.

1999We conclude, as did the en banc Superior Court, 451 Pa.Super. 136 , 678 A.2d 802 , that the pollution exclusion clause operates to bar coverage in the present case, and therefore affirm.

11999–1999
Morton International, Inc. v. General Accident Insurance green
nj · 1993
2 sentences

1999Id.

1999Id.

11999–1999
Standard Venetian Blind Co. v. American Empire Insurance green
pa · 1983
2 sentences

1999The court’s only aim, as noted earlier, must be “to ascertain the intent of the parties as manifested by the language of the written instrument....” 7 Gene & Harvey, 512 Pa. at 426 , 517 A.2d at 913 (quoting Standard Venetian Blind, 503 Pa. at 305 , 469 A.2d at 566 ) (emphasis added).

1999The court’s only aim, as noted earlier, must be “to ascertain the intent of the parties as manifested by the language of the written instrument....” 7 Gene & Harvey, 512 Pa. at 426 , 517 A.2d at 913 (quoting Standard Venetian Blind, 503 Pa. at 305 , 469 A.2d at 566 ) (emphasis added).

11999–1999
Techalloy Co. v. Reliance Insurance green
pa · 1984
2 sentences

1997Plaintiffs recognize that at this time they cannot recover in this court by arguing that the plain and ordinary meaning of the words in the pollution exclusion clause permits an interpretation which excludes coverage only in cases of intentional pollution — i.e., where the property damage was either expected or intended by the insured. 2 The Pennsylvania Superior Court has consistently ruled that this standard pollution exclusion bars coverage for “any unintentional release or dispersal of pollution that occurs gradually over time”; there is coverage only where a discharge is “both sudden, mea

1997Plaintiffs recognize that at this time they cannot recover in this court by arguing that the plain and ordinary meaning of the words in the pollution exclusion clause permits an interpretation which excludes coverage only in cases of intentional pollution — i.e., where the property damage was either expected or intended by the insured. 2 The Pennsylvania Superior Court has consistently ruled that this standard pollution exclusion bars coverage for “any unintentional release or dispersal of pollution that occurs gradually over time”; there is coverage only where a discharge is “both sudden, mea

11997–1997
Krause v. Great Lakes Holdings, Inc. green
pa · 1989
1 sentence

1997Krause v. Great Lakes Holdings Inc., supra at 67, 563 A.2d at 1187 .

11997–1997

Statutes the citing opinions construe

USC § 42u.s.c.4851 (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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