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SVB Underwriting, Ltd. - Memorandum of Decision","","Hartford Steam Boiler Group, Inc. (HSB) sued SVB Underwriting, Ltd. over an insurance coverage dispute following a 1999 explosion at the Clara Barton Convalescent Center in Flint, Michigan. The court describes a natural-gas leak and extensive resulting wrongful death and personal injury litigation, including settlements and defense/arbitration costs. SVB invoked “Exception M” excluding claims known to HSB’s general counsel by December 1, 2000, while HSB sought recovery of settlements and litigation expenses.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/hartford-steam-boiler-group-inc-v-svb-underwriting-ltd-memorandum-of-decision/278483/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/hartford-steam-boiler-group-inc-v-svb-underwriting-ltd-memorandum-of-decision/278483.png","ImageObject",442,249,{"name":88,"@type":89},"Skyler","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-27","2026-09-15",true,{"@type":98,"interactionType":99,"userInteractionCount":25},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"What incident triggered the dispute between HSB and SVB Underwriting?","Question",{"text":108,"@type":109},"A boiler-room explosion at the Clara Barton Convalescent Center on November 10, 1999, caused by a natural gas leak, significantly damaging the facility and resulting in fatalities and injuries.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"What insurance issue was at the core of the lawsuit?",{"text":113,"@type":109},"Whether SVB’s policy coverage was excluded by “Exception M,” which bars coverage for claims or circumstances reasonably expected to give rise to claims known to HSB’s general counsel as of December 1, 2000.",{"name":115,"@type":106,"acceptedAnswer":116},"How were the underlying claims resolved before the court’s decision?",{"text":117,"@type":109},"HSB settled Michigan wrongful death and personal injury suits in 2004 for $7.35 million, and later resolved a related subrogation matter through arbitration in 2006 for $1.3 million, plus incurred $2.2 million in defense costs.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},278483,1790757003,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":25,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":135,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":141},2336464648746,"https://ap-avatar.wpscdn.com/davatar_276721f389ce27ea32af1340a28f341c","UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT  \nHARTFORD STEAM BOILER GROUP, INC.,  \nPlaintiff,  \nv.  \nSVB UNDERWRITING, LTD., Defendant.  \nNo. 3:04cv2127 (SRU)  \nMEMORANDUM OF DECISION  \nThis case is an insurance coverage dispute arising from an explosion that originated in the boiler room of the Clara Barton Convalescent Center (“Clara Barton”) in Flint, Michigan, on November 10, 1999.1 The explosion significantly damaged Clara Barton, killed five people, and injured many others. The explosion was caused by a natural gas leak, but the cause of the leak was never determined.  \nHartford Steam Boiler Group, Inc. (“HSB”), the plaintiff, is an equipment breakdown insurer that also inspects boilers.2 After the Clara Barton explosion, numerous wrongful death and personal injury lawsuits were filed in Michigan state courts, including seventeen suits alleging, inter alia, negligence by HSB in its inspection of the boiler, and one subrogation suit by Clara Barton’s property and casualty insurer against HSB. In 2004, HSB settled the personal injury and wrongful death suits for $7.35 million. Two years later, HSB resolved the subrogation suit through arbitration for $1.3 million. HSB also spent $2.2 million in defense costs.  \n1 The plaintiff is a corporation with its primary place of business in Connecticut, and the defendant is a corporation with its primary place of business in England. Accordingly, in light of the significant sums at issue, the court has diversity jurisdiction over this claim pursuant to 28 U.S.C. § 1332.  \n2 Throughout this opinion,“boiler” and “pressure vessel” will be used interchangeably.  \nIn 2000, HSB took out an insurance policy with certain underwriters, including the defendant, SVB Underwriting, Ltd. (“SVB”) .3 That policy provided HSB with errors andomissions (“E&O”) insurance coverage, including defense costs. “Exception M” to the policy excluded coverage for claims, or circumstances that could reasonably be expected to give rise to claims, known to the office of general counsel as of December 1, 2000. SVB argued that this exception covered the explosion at Clara Barton, which was not reported to SVB before the policy was issued. HSB disagreed, and argued that it should be able to recover from SVB for the settlements ofthe underlying suits as well as for litigation and arbitration costs sustained as a result of the litigation concerning the Clara Barton explosion.  \nA bench trial began on January 10, 2011 and ended on January 11, 2011. My findings of fact and conclusions of law are set forth below.  \nI. Background  \nA. Undisputed Facts  \nHSB is one of the largest equipment and machinery insurers in the United States. HSB specializes in equipment breakdown policies; because property and casualty insurance policies generally preclude coverage for equipment breakdowns, HSB’s insurance is often used to supplement those policies. HSB also conducts boiler certification inspections of insured equipment in accordance with applicable state and city codes. Those inspections are commonly referred to as “jurisdictional inspections.” HSB performs approximately 500,000 jurisdictional inspections per year.  \nOn November 10, 1999, an explosion occurred inside the boiler room at Clara Barton, destroying a substantial portion of the building, killing five people, and injuring numerous  \n3 Although SVB is now known as Novae Underwriting, Ltd., it will be referred to as SVB throughout this decision.  \nothers. Clara Barton had purchased an insurance policy from HSB, and if the damage had been caused by a boiler explosion, HSB would have had to reimburse Clara Barton for the property damage and lost income that resulted from the explosion. In connection with its equipment breakdown policy, HSB had also conducted periodic jurisdictional inspections ofthe heating boiler inside Clara Barton.4 The last such inspection was conducted by Herbert Wathan, an HSB employee, on November 24, 1998. Officials ultimately determined tha","cbCairQu1qb22W9m","https://ap.wps.com/l/cbCairQu1qb22W9m","pdf",266639,25,"English","# Memorandum of Decision\n## Background\n### Undisputed Facts","[{\"question\":\"What incident triggered the dispute between HSB and SVB Underwriting?\",\"answer\":\"A boiler-room explosion at the Clara Barton Convalescent Center on November 10, 1999, caused by a natural gas leak, significantly damaging the facility and resulting in fatalities and injuries.\"},{\"question\":\"What insurance issue was at the core of the lawsuit?\",\"answer\":\"Whether SVB’s policy coverage was excluded by “Exception M,” which bars coverage for claims or circumstances reasonably expected to give rise to claims known to HSB’s general counsel as of December 1, 2000.\"},{\"question\":\"How were the underlying claims resolved before the court’s decision?\",\"answer\":\"HSB settled Michigan wrongful death and personal injury suits in 2004 for $7.35 million, and later resolved a related subrogation matter through arbitration in 2006 for $1.3 million, plus incurred $2.2 million in defense costs.\"}]","Hartford Steam Boiler Group, Inc. v. SVB Underwriting, Ltd. - Memorandum of Decision | PDF",1789510319,9]