Contents


    Executive Summary

    The coronavirus disease, or COVID-19, is an infectious disease caused by a newly discovered coronavirus that emerged in December 2019. The World Health Organization (WHO) declared COVID-19 a Public Health Emergency of International Concern on January 30, 2020, and a pandemic on March 11, 2020. Since then, there have been over 774 million reported COVID-19 cases globally, resulting in more than 7 million deaths, according to the WHO. Of those totals, the United States has experienced 103 million reported infections and over 1 million COVID-19 related deaths (as of February 15, 2024). COVID-19 vaccines became available for emergency use in various countries starting in late 2020. These vaccines have played a crucial role in efforts to control the spread of the virus and mitigate the impact of the pandemic. After 3 years of navigating the challenges and uncertainties of the pandemic, the U.S. Department of Health and Human Services declared the COVID-19 public health emergency officially over as of May 11, 2023.

    Although COVID-19 remains an important public health threat given its potential to cause severe disease among vulnerable individuals, it is no longer the public health crisis it once was. COVID symptoms increasingly resemble those of other respiratory viral illnesses, like the flu and RSV. As such, the CDC recently published updated guidelines that advise individuals to adopt similar precautions for COVID as those typically taken for other respiratory illnesses. The revised guidelines acknowledge the reduced severity of the virus and allow for the consideration of other crucial health and societal concerns. See additional RAA resources on the COVID-19 page of the RAA website.

    Background

    COVID-19 is the first time the WHO has named an outbreak as a pandemic since the H1N1 (swine flu) in 2009. A pandemic is the highest level of a health emergency and is defined as “an epidemic occurring worldwide, or over a very wide area, crossing international boundaries and usually affecting a large number of people.” Unlike a widespread epidemic, a pandemic disease infects an unstable number of people; a pandemic affects an even wider geographic area and infects an exceptionally high proportion of the global population.

    The emergence of COVID-19, caused by the novel coronavirus SARS-CoV-2 marked a significant global health crisis. The WHO was first notified of the coronavirus threat when the Chinese government reported a cluster of pneumonia cases in the Hubei Province’s City of Wuhan on December 31, 2019. Since then, the disease has ravaged the world, affecting 229  countries and territories with particularly devastating effects in China, Italy, Spain, India, Brazil, Russia, Columbia, Mexico and the United States. The virus belongs to the family of coronaviruses, known for their ability to cause respiratory illnesses ranging from the common cold to more severe diseases. The unique characteristic of SARS-CoV-2 is its high transmissibility, which fueled its rapid spread worldwide. The virus spreads primarily through droplets of saliva or discharge from the nose.

    COVID-19 quickly garnered attention from the international community, prompting the WHO to declare it a Public Health Emergency of National Concern on January 30, 2020. As cases surged worldwide, the WHO officially declared COVID-19 a pandemic on March 11, 2020, reflecting the virus’s widespread transmission and the gravity of its impact on global health systems and economies. The pandemic led to unprecedented disruptions in daily life, with governments implementing various measures such as lockdowns, travel restrictions, closure of non-essential businesses and social distancing guidelines to curb transmission. The virus’s impact extended well beyond public health, causing widespread economic repercussions, straining healthcare systems, and highlighting global inequities in access to healthcare and resources.

    The pandemic laid bare the vulnerabilities of the U.S. healthcare system, exposing disparities in access to care and insufficiency of resources. Hospitals and healthcare facilities faced shortages of critical supplies including personal protective equipment (PPE), ventilators, and ICU beds as they confronted the overwhelming surge of COVID-19 patients. Healthcare workers worked tirelessly on the frontlines, risking their lives to provide care to those affected by the virus.

    The economic impact of the COVID-19 pandemic was significant, with widespread job losses, business closures, and financial hardships affecting millions of Americans. Sectors such as hospitality, retail, and entertainment bore the brunt of the economic downturn. In response, the federal government enacted a series of stimulus packages and relief measures aimed at providing much-needed support to individuals, businesses, and industries reeling from the pandemic’s impact. Measures included direct payments to individuals, expanded unemployment benefits, forgivable loans for small businesses, and financial assistance for hard-hit sectors of the economy. Unfortunately, disparities in access to financial assistance and support were also prevalent, exacerbating existing inequalities.

    Efforts to combat COVID-19 were focused on multiple fronts, including vaccine development, therapeutic treatments, and public health interventions. Scientists around the world raced to create effective vaccines, resulting in the unprecedented rapid development and deployment of multiple COVID-19 vaccines authorized for emergency use. Vaccination efforts have been critical in mitigating the spread of the virus, and reducing severe illness and death, contributing significantly to the eventual declaration of the end of the public health emergency.

    Injuries and Damages

    The COVID-19 pandemic disrupted nearly every aspect of our daily lives. Schools, businesses, and publicly shared spaces experienced unprecedented interruptions and state-ordered closures.

    Education
    COVID-19 profoundly disrupted education in the United States, forcing schools at all levels to adapt rapidly to remote learning environments. At the peak of the pandemic, the closures affected at least 55.1 million students in 124,000 U.S. public and private schools. Nearly every state either ordered or recommended that schools remain closed through the end of the 2019-20 school year. The abrupt and widespread shutdown disrupted the lives of students, parents, and educators alike, forcing them into a new and challenging educational landscape. This shift exposed deep disparities in access to technology and internet connectivity, exacerbating existing inequalities. Students from low-income families and marginalized communities faced greater challenges in accessing remote learning resources leading to a widening of the achievement gap. Additionally, the sudden shift also placed immense strain on teachers who had to quickly develop new teaching methods and adapt curriculum to online platforms, often without adequate training or resources.

    Additionally, the pandemic disrupted traditional modes of instruction and social interaction, impacting students’ mental health and overall wellbeing. Many students struggled with feelings of isolation and disengagement as they navigated remote learning without the in-person support of teachers and peers. The closure of schools also disrupted vital support services, such as meals and counseling, further exacerbating the challenges faced by vulnerable students. As schools grappled with the complexities of remote learning, debates over reopening plans sparked contentious discussions among policymakers, educators, and parents, reflecting the tension between public health concerns and the imperative to ensure access to quality education.

    Business Closures
    At the peak of the pandemic, the majority of states in the U.S. implemented measures mandating the closure of nonessential businesses, leading to significant disruptions across various industries. Essential businesses such as supermarkets, pharmacies, and healthcare facilities remained operational, while nonessential establishments like retail stores, gyms, and movie theaters were closed. Restaurants also faced various closure restrictions with some states allowing for outdoor dining options while prohibiting indoor dining, while others imposed more stringent restrictions that temporarily closed restaurants altogether except for takeout and delivery.

    While the onset of the pandemic resulted in many businesses temporarily closing, by October 2021 85% of those local businesses were able to reopen, according to a report published by Yelp. Even amidst growing concerns of inflation, supply chain constraints and a labor shortage, Yelp data indicates new business openings increased 14% in 2021. Recent data from the U.S. Census Bureau reveals this surge in startup activity has continued. In October 2023, the IRS received 473,000 applications for new businesses, with 154,000 of these likely to become new employer enterprises, marking a significant 41% increase compared to October 2019.

    The Federal Reserve also published a study in 2022 that contains useful insights related to business entry and exit during the pandemic. The research reiterates that in the early stages of the pandemic there was a surge in establishment closures, many of which were temporary and reopened shortly thereafter. However, there was also a significant increase in permanent establishment exits, resulting in the loss of nearly 1.2 million jobs in the second quarter of 2020, according to data from the Bureau of Labor Statistics (BLS). In contrast, the latter half of 2020 witnessed a significant rise in “establishment births”, which was consistent with previously reported Business Formation Statistics (BFS) data on new business applications. Overall, the proliferation of new businesses far outnumbered permanent closures. This has resulted in a shift of the distribution of firm sizes, with a larger portion of both firms and employment now attributed to smaller businesses. However, this trend is also influenced by existing firms reducing their size, contributing to the prevalence of smaller size categories.

    Teleworking and Unemployment
    Amidst the evolving landscape of U.S. workplaces, the COVID-19 pandemic catalyzed a monumental shift towards remote work, reshaping the dynamics of employment nationwide. According to a Pew Research Center survey, roughly three years after the onset of the pandemic, about one third (35%) of employees whose roles allow for remote work are now exclusively working from home. This figure marks decline from 43% in January 2022 and 55% in October 2020, but represents a significant increase from the pre-pandemic rate of only 7%. Additionally, a growing number of employees have shifted to working a hybrid schedule where they work from home some days and from the office other days. The same Pew survey found that 41% of those with jobs that can be done remotely are working on a hybrid schedule. About six-in-ten hybrid workers (59%) say they work from home three or more days in a typical week, while 41% say they do so two days or fewer. The shift to remote work has become a defining feature of the modern workforce, profoundly impacting how businesses operate and employees collaborate.
    The drastic and sudden shift to remote work presented a wide range of both burdens and benefits. Some benefits of remote work include less time commuting on the road, greater worker productivity, reduced greenhouse gas emissions, money saved, higher job satisfaction, more time for family and fitness, and lessened exposure to communicable diseases. On the other hand, some risks of working from home may include more distractions, loss of productivity, security concerns, new opportunities for hackers, management difficulties, communication inadequacies, and a lack of community and workplace culture.

    During the pandemic, the U.S. experienced its highest levels of unemployment since the Great Depression. According to the Bureau of Labor Statistics, the unemployment rate peaked at 14.8% in April 2020, and the number of unemployed Americans reached 20.5 million by May 2020. This spike in unemployment was primarily attributed to widespread closures of nonessential businesses, stay-at-home orders, and other measures implemented to curb the spread of the virus. Millions of workers across various industries were laid off or furloughed as economic activity slowed dramatically.

     
    The COVID-19 recession initially suggested a slow recovery due to record-high unemployment and a sharp decline in GDP. However, targeted fiscal measures, including expanded social safety nets and a robust federal vaccination program were effective in preventing a prolonged recovery. As a result, the COVID-19 recession lasted only two months according to the National Bureau of Economic Research. Subsequently, the U.S. experienced a swift and more equitable economic recovery compared to other recessions, marked by record-high employment rates for women aged 25 to 54 and historically low unemployment rates for Black and Hispanic workers.

    Supply Chain Disruption
    The disruption to global supply chains unfolded rapidly in the wake of COVID-19. As the virus spread globally and countries implemented stringent lockdown measures, factories, ports and transportation networks ceased operations. This sudden halt in economic activity disrupted the flow of goods and materials at every stage of the supple chain, from production to distribution. Borders closed, leading to delays in cross-border trade and exacerbated existing shortages of critical supplies. Compounding the issue, workforce shortages due to illness or quarantine further strained production capacities. The interconnectedness of modern supply chains magnified the impact, as disruptions in one region reverberated across the globe. Among the hardest hit industries were those reliant on global manufacturing and distribution networks. These included: oil, apparel, technology, and construction and building material. Companies scrambled to adapt, seeking alternative sourcing strategies and diversifying supply chains to mitigate risks.

    Medical Unpreparedness
    The ideal goal in fighting a pandemic is to completely halt the spread of the disease. But mitigating its spread is critical to “flattening the curve.” The reproduction number (R0) of the COVID-19 viral pathogen was initially estimated to be as high as 3.5, meaning each infected person could potentially transmit the virus to 3.5 others. Variations in the R0 have been observed over time as the virus mutated and new strains emerged. For example, the Delta variant of the virus proved to be more transmissible and studies suggested that the R0 was anywhere between 5 to 8. Social-distancing measures were employed to lower the R0 and potential transmission rate due to hospital capacity. Most hospitals can only function with a ten percent reduction in staff. Slowing the spread and “flattening the curve” refer to efforts to maintain a stable number of new cases below peak healthcare system capacity.

    Even with widespread social distancing measures, the United States still grappled with significant unpreparedness during the pandemic, characterized by a deficiency in testing capabilities, limited access to personal protective equipment (PPE), and a shortage of ventilators. The absence of a coordinated federal response during these crucial early months of the pandemic exacerbated these challenges, leaving local health departments competing for scarce resources. Despite the urgent need for widespread diagnostic testing to curb the spread of the virus, testing remained inconsistent across regions even months into the pandemic. The lack of a cohesive federal testing strategy tailored to meet regional demands hampered efforts to contain outbreaks effectively. Additionally, initial estimates suggested a stark disparity between the available ventilator supply, estimated between 60,000 to 160,000 units, and the potential need, which experts projected could reach up to one million. As hospitals faced overwhelming patient loads, governors resorted to loaning ventilators to states most heavily impacted, such as New York and New Jersey, underscoring the strain on critical medical resources.

    Regulatory Retaliation
    In the wake of the pandemic, regulatory retaliation became a significant concern. According to a report published by the U.S. Treasury Department, COVID-19 closure losses for small businesses were between $255 billion and $431 billion per month. Using the Insurance Information Institute’s estimate that 30-40% of small businesses carry Business Interruption (BI) Insurance, these losses could translate to insurance exposures of $76.5-172.4 billion per month. These losses are exceptionally large, especially considering that monthly premiums for commercial property insurance total only $6 billion.

    Many small business owners filed claims for business interruption insurance payouts only to discover that their insurance carriers exclude coverage for viruses. Mass denial of claims has led to a surge of lawsuits against insurance companies with allegations of bad faith and breach of contract. The key issue in COVID-19 cases is whether the presence of the coronavirus and the state-mandated business closures constitute the “property damage and physical loss” necessary to trigger coverage for business interruption. In addition to policyholders primarily seeking redress through litigation, lawmakers also began introducing legislation aimed at compelling insurers to retroactively cover BI losses. According to the NAIC, by August 2020, ten states (New York, Massachusetts, New Jersey, Louisiana, Ohio, Pennsylvania, Rhode Island, California, Michigan, and South Carolina) had proposed legislation aimed at compelling insurers to retroactively pay for BI losses resulting from COVID-19 shutdowns. Some of the bills apply only to claims from small businesses with less than 250 employees and others would allow insurers to seek partial reimbursement from the states. Though the insurance industry maintains an $800 billion surplus to cover U.S. home, auto, and business insurance claims, industry experts urge that it is necessary to keep this surplus stable in case of increased natural disasters. Furthermore, the President and CEO of American Property Casualty Insurance Association, David Sampson, asserted that, “Pandemic outbreaks are uninsured because they are uninsurable.”

    Some legal scholars argue that such legislation could be challenged on constitutional grounds under the Contracts Clause of the U.S. Constitution, which bars states from retroactively changing contract terms. Though other scholars speculate that these challenges would be unsuccessful, since the prohibition against state ex post facto laws applies only to penal and criminal legislation, and not to civil laws that adversely affect private rights. Furthermore, the scope of legislative “impairment” of contract has remained judicially uncertain, though it is generally accepted that the government retains adequate authority to secure the good order of society; and this authority is typically viewed as superior to that of individual contract rights. Nevertheless, insurance industry experts argue that, if passed, the state legislation would result in sweeping payout requirements that are unfeasible in the long-term. Thomas Bentz, an attorney and industry expert, concluded, “Insurance works really well when you have a small localized loss and you spread it out. Insurance doesn’t work where everyone has the same loss at the same time. If you have 100% loss across your portfolio, it’s not sustainable.” Amidst these unresolved legislative complexities, companies have increasingly turned toward litigation as their primary course of action in addressing BI coverage for COVID-19 related damages.

    Legislation and Regulation

    Federal Legislation

    The CARES Act

    The Coronavirus Aid, Relief, and Economic Security Act (The CARES Act, Public Law 116-136) was passed with bipartisan support from the 116th Congress and was signed into law by President Donald Trump on March 27, 2020. The bill included an economic relief package for over $2 trillion to aid Americans in navigating the public health and economic impacts of the COVID-19 pandemic and economic crisis. The CARES Act included measures aimed at providing direct assistance to individuals and families, supporting small businesses, aiding state and local governments and bolstering healthcare resources. CARES Act funds expired on September 30, 2021.

    The Act provided Economic Impact Payments to American workers and families whose income was less than $99,000, or $198,000 for joint filers. The impact payments were administered by the Internal Revenue Service (IRS) of the Department of the Treasury through one-time stimulus checks of $1,200 per adult whose income was below the recovery line and $500 per child under 17 years old, or up to $3,400 per family of four. Following the initial round of stimulus payments under the CARES Act, subsequent legislation, such as the Consolidated Appropriations Act, 2021 and the American Rescue Plan Act of 2021, authorized additional rounds of stimulus payments with adjusted eligibility criteria and payment amounts to provide ongoing support to individuals and families affected by the pandemic.

    The bill also established the Paycheck Protection Program (PPP), which emerged as a vital lifeline for countless small businesses across the US. Launched in April 2020, the PPP aimed to alleviate economic strain by offering forgivable loans to eligible businesses, enabling them to maintain payroll, cover essential operating costs, and sustain their workforce amidst the unprecedented challenges. Under the program, businesses could utilize funds for payroll costs, rent, utilities, and mortgage interest, with the potential for full loan forgiveness if specific criteria were met. These criteria included spending at least 60% of the loan proceeds on payroll costs over a designated period, typically eight or 24 weeks from the disbursement of the loan. Additionally, businesses were required to maintain their pre-pandemic levels of full-time equivalent employees or demonstrate efforts to rehire employees who were laid off or had their hours reduced. Meeting these conditions was essential for businesses to qualify for full or partial loan forgiveness, ensuring that the funds were utilized in a manner consistent with the program's objective of supporting employee retention and essential operational expenses. Despite initial implementation hurdles and adjustments, the PPP proved to be vitally important in helping millions of small businesses sustain their operations.

    The CARES Act also established the $150 billion Coronavirus Relief Fund to provide payments to state, local, and tribal governments to combat the impacts of the COVID-19 outbreak. Treasury has made payments from the Fund to States and eligible units of local government; the District of Columbia and U.S. territories, and Tribal governments. The Act requires that payments from the Coronavirus Relief Fund only be used to cover expenses that:

    1. Are necessary expenditures incurred due to the COVID-19 public health emergency;
    2. Were not accounted for in the budget as of March 27, 2020 for the state or local government; and
    3. Were incurred during the period that begins on March 1, 2020, and ends on December 31, 2022.

    The Consolidated Appropriations Act, 2021

    The Consolidated Appropriations Act, 2021 was enacted with broad bipartisan support from the 116th Congress and signed into law on December 27, 2020, by then-President Donald Trump. This comprehensive legislation responded to the ongoing challenges posed by COVID-19 and the accompanying economic downturn. The legislation combined a $1.4 trillion omnibus spending bill with a $900 billion COVID-19 relief package in an effort to provide continued assistance to those grappling with the impacts of the pandemic. Notable provisions of the relief package included another round of direct stimulus payments to eligible Americans, an extension and enhancement of Federal Pandemic Unemployment Compensation program, and additional funding and stricter guidelines for the Paycheck Protection Program in order ensure that funds were being directed toward businesses most in need.

    Additionally, the Act allocated funding for critical pandemic response efforts, including vaccine distribution, expanding testing capabilities, and supporting healthcare providers. It also included provisions for rental assistance, education funding, and support for industries severely impacted by the pandemic, such as airlines and hospitality.

    American Rescue Plan Act of 2021

    The American Rescue Plan of 2021 (ARP), signed into law by President Biden on March 11, 2021, was a comprehensive piece of legislation aimed at providing relief in the wake of the pandemic. Economically, the ARP served as a robust stimulus package, injecting billions of dollars into the economy through direct payments to individuals, expanded unemployment benefits, and assistance to businesses. These measures provided crucial financial support to millions of Americans grappling with job losses, reduced income, and other challenges stemming from the economic downturn.

    The ARP provided additional direct stimulus payments to eligible Americans. Individuals earning less than $75,000 a year and couples earning up to $150,000 a year received $1,400 per person, including dependents. Additionally, unlike previous stimulus payments, adult dependents, such as college students and disabled individuals, were also eligible for the full payment. The ARP also included measures to address child poverty by expanding the Child Tax Credit and making it fully refundable. This expansion lifted millions of children out of poverty, offering vital support to low- and middle-income families struggling to cover essential expenses like food, housing, and healthcare. In the realm of public health, the ARP allocated significant funding for vaccine distribution, COVID-19 testing, and contact tracing efforts. This funding played a pivotal role in accelerating the nationwide vaccination campaign, expanding access to vaccines, and curbing the spread of the virus.

    Education and childcare also received substantial attention under the ARP, with significant funding directed toward supporting the safe reopening of schools and childcare facilities. This investment helped institutions implement COVID-19 mitigation measures, enhance ventilation systems, and provide resources for remote learning. Additionally, the ARP expanded subsidies for childcare and early education programs, making them more affordable for families grappling with the challenges posed by the pandemic.

    Furthermore, the ARP provided critical aid to state and local governments, delivering $350 billion in direct assistance to help address budget shortfalls, maintain essential services, and support pandemic response efforts. This funding played a crucial role in preventing layoffs of essential workers, ensuring the continuation of vital services, and supporting local economies. Additionally, the ARP included provisions to increase access to affordable healthcare coverage through subsidies for health insurance premiums, expanding healthcare access during a time of heightened need.

    Pandemic Risk Insurance Act of 2020

    Escalating losses to businesses and a growing number of policyholder lawsuits spurred momentum for federal support of pandemic risk insurance. In response, the Pandemic Risk Insurance Act (PRIA) was introduced in May 2020 with the aim of creating a government backstop for pandemic insurance. The proposed legislation would create a program similar to the Terrorism Risk Insurance Act (TRIA) created in the aftermath of 9/11. A discussion draft of the bill was proposed by Congresswoman Carolyn Maloney, a democrat from New York. Administered by the Department of the Treasury, PRIA would be triggered once industry losses exceed a $250 million threshold and aggregate losses would be capped at $750 billion for both the government and insurers.

    In return for a federal backstop on pandemic losses, insurers would agree to make business interruption insurance coverage available for insured losses that do not “differ materially from the terms, amounts and other coverage limitations applicable to losses arising from events other than public health emergencies.” Similar to the 9/11 program, participating insurers would be subject to a deductible and co-pay. Losses in excess of each insurer’s deductible would be shared between the federal government and the insurer, with the government paying 95 percent of excess losses. Following its initial introduction in the House of Representatives in May 2020, the bill was reintroduced by Congresswoman Maloney in November 2021, and has yet to gain any real traction.

    HEROES Act

    On May 15, 2020, the House of Representatives passed the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES Act) by a vote of 208-199. Despite passing in the House, the HEROES Act faced significant opposition in the Senate where several lawmakers voiced concerns about its cost and specific provisions. Negotiations between Democrats and Republicans stalled and the bill was not enacted into law in its original form. However, elements of the proposal were incorporated into subsequent legislative packages, such as the Consolidated Appropriations Act, 2021, and the American Rescue Plan Act of 2021, which provided additional economic relief and support in response to the ongoing pandemic.

    Stop COVID Act

    Senators Marsha Blackburn (R-TN) and Martha McSally (R-AZ) introduced the Stop China-Originated Viral Infectious Diseases (COVID) Act to allow Americans to seek damages from China in federal court. If enacted, the Stop COVID Act would amend the Foreign Sovereign Immunities Act (FSIA) to establish an exception to jurisdictional immunity for a foreign state that discharges a biological weapon. The senators have said that FSIA acts as a shield for the Chinese government to hide behind after repeatedly lying and spreading propaganda about the nature and numbers of the coronavirus pandemic. The Bill was read twice and referred to the Senate Judiciary Committee, where it has not gained any significant momentum.

    Facilitating Innovation to Fight Coronavirus Act

    On March 30, 2020, Senator Ben Sasse of Nebraska introduced this bill to provide a “common-sense” liability shield for healthcare professionals fighting coronavirus. The legislation gives emergency liability and patent protections to doctors and nurses to limit the likelihood of future lawsuit. The bill would limit liability for:

    1. Using or modifying a medical device for an unapproved use or indication;
    2. Practicing without a license or outside of an area of specialty if instructed to do so by an individual with such a license or within such an area of specialty;
    3. Conducting the testing of, or provision of treatment to, a patient outside of the premises of standard health care facilities.

    The Bill was read twice and referred to the Senate Judiciary Committee, where it has not gained any significant momentum.

    State Legislation

    Note: This section is meant to provide examples of various legislation circulating state legislative bodies. For a more comprehensive overview of pending state regulations, please see:

    Massachusetts Liability Bill
    An Act to Provide Liability Protections for Health Care Workers and Facilities During the COVID-19 Pandemic. Signed into law on April 17, 2020, by MA Governor Charlie Baker, the legislation seeks to provide health care workers and facilities with protections from civil liability for actions taken while working on the frontlines of the state’s COVID-19 response. Governor Baker also issued a directive to maximize protections for health care workers under the federal Public Readiness and Emergency Preparedness Act (PREP Act) during the state of emergency. The directive will ensure that those who distribute and administer testing, drugs and medical devices for the diagnosis and treatment of COVID-19 are protected from liability, absent gross negligence, to the maximum extent possible. The legislation seeks to protect workers and facilities who are operating on limited information and with minimal direction as COVID-19 is a constantly changing and developing situation.
    Georgia Executive Order
    On April 14, 2020, Georgia Governor Brian Kemp signed an Executive Order designating that employees, staff, and contractors of healthcare institutional and medical facilities shall be considered auxiliary emergency management workers. This designation provides such emergency management workers with immunity from personal injury lawsuits during the crisis should a patient be injured or die under their care. Along with hospitals, the order also includes surgical and diagnostic centers, mobile clinics, rehabilitation centers, nursing homes, and assisted living communities. The order does not limit immunity to issues related to COVID-19. It does not, however, protect staff or facilities from liability in the case of intentional harm or actions amounting to “gross negligence.”
    Va. Code § 8.01-225.02. Certain liability protection for health care providers during disasters.
    The state of Virginia has a statute providing that, in the absence of gross negligence or willful misconduct, any health care provider who responds to a disaster shall not be liable for injury or wrongful death of any person arising from the delivery or withholding of healthcare when:
        i. A state or local emergency has been declared; and
        ii. The emergency and subsequent conditions caused a lack of resources.
    Under these conditions, liability protections are offered when health care workers are unable to provide the level or manner of care that would otherwise be required in the absence of the emergency/disaster. Other states are providing liability protections to healthcare workers and volunteers providing care during the COVID-19 outbreak.

    Liability and Insurance

    Business Interruption Insurance
    As the pandemic triggered government ordered shutdowns of millions of businesses across the United States, policyholders have sought to recover lost income by filing business interruption claims. Business interruption insurance is generally an add-on to a commercial property policy. Some estimates suggest that the average small business was losing anywhere from $10,000 to $30,000 or more per month during the height of the pandemic, which translates to billions of dollars in losses nationwide each month. According to a report by the U.S. Chamber of Commerce, small businesses alone lost an estimated $255 billion in revenue during the first three months of the pandemic (March to May 2020). In order to recoup some of these losses, businesses began filing business interruption claims. However, numerous insurance companies contested these claims arguing that coverage doesn’t apply to income loss from shutdowns due to the coronavirus. They argued that most policies include the requirement that loss must result from actual or direct physical loss or damage to property. Additionally, policies often include a virus and bacterial exclusion; such exclusions were worked into many insurance policies in the wake of the SARS, Zika, and Ebola outbreaks. Consequently, a wave of legal battles ensued across various states, with businesses ranging from restaurants to retailers filing lawsuits against insurers. Courts have grappled with interpreting policy language and determining whether government-mandated closure constitute a form of physical damage or loss sufficient to trigger coverage. Rulings across the country have varied, with some courts siding with insurers pointing to the exclusionary policy language, while others have favored policyholders. For example, in North Carolina, a federal judge ruled in favor of a group of restaurants concluding that the closure orders issued by the state constituted a covered loss under their insurance policies. The judge emphasized that the orders had directly caused physical loss or damage to the insured properties, despite the absence of physical alteration. Similarly, in Missouri, a state court judge handed down a significant victory for policyholders, ruling that a policy provision that provided coverage for losses stemming from government actions applied to the pandemic-related shutdown orders. The judge rejected the insurer's argument that the closures did not constitute physical damage or loss, emphasizing the economic harm suffered by the insured businesses. Conversely, in February 2024, the New York Supreme Court upheld lower court rulings denying BI coverage for COVID-19 related losses, affirming that the presence of the virus alone does not fulfill the requirement for physical loss or damage under the insurance policy in question. The legal landscape remains dynamic, with appeals and divergent rulings in different jurisdictions contributing to ongoing uncertainty for businesses and insurers alike.

    Auto Insurance
    At the height of the pandemic, business shutdowns, school closures, and stay-at-home orders significantly reduced traffic nationwide, prompting many major U.S. auto insurers to return a portion of premiums to policyholders due to decreased accident rates. These relief measures typically resulted in a 15 to 25% reduction in customers’ premium payments for one or more months during the spring of 2020, according to the Insurance Information Institute. The initiative collectively returned $14 billion to policyholders, with several companies extending refunds initially announced for April and May through June 2020.

    Medical Malpractice and Liability
    Initially, some experts voiced concerns about a potential surge in medical malpractice claims, fueled by the uncertainties surrounding the novel virus and the unprecedented challenges faced by healthcare providers. Medical providers, particularly those on the frontlines, lobbied lawmakers for liability protection to shield themselves from potential lawsuits. The American Medical Association and other leading groups were instrumental in engaging with local governments to advocate for legal safeguards over liability concerns amid a notable surge in COVID-19 hospitalizations. Doctors have urged that they need better legal guards against unreasonable claims. For practitioners in states without caps on damages, medical malpractice insurance premiums may cost some specialists upwards of $100,00 per year. Governors in New Jersey, New York, and Michigan have responded with orders that raise the standard for medical malpractice from pure negligence to “gross negligence” where only an egregious deviation from standard care would justify a lawsuit. These governors asserted that in unprecedented times, insurance regulations should be tailored to the circumstances of the crisis. On the other hand, plaintiffs’ representatives discouraged widespread liability shields. They voiced concerns about healthcare providers adopting untested treatment plans and using “hastily-designed” medical equipment during the pandemic. However, when it comes to infectious diseases, the unprecedented circumstances of this pandemic may present those who would potentially file suit with a higher causation hurdle.

    Worker’s Compensation
    Worker’s compensation is a form of insurance that provides wage and medical coverage to employees injured on the job within the course of their employment. In exchange, employees relinquish their right to sue employers for negligence, absent willful or wanton disregard for safety. The Occupational Safety and Health Administration (OSHA) requires employers to establish a workplace that’s “free from recognized hazards that are causing or are likely to cause death or serious physical harm” to employees. During the reopening of non-essential businesses, worker’s compensation and workplace safety became paramount concerns. OSHA advised businesses to follow Centers for Disease Control and Prevention (CDC) guidelines. These guidelines included instructing employees to maintain a six-foot distance from others, conducting temperature checks, disinfecting surfaces regularly, and providing personal protective equipment (PPE) such as face masks, hand sanitizers, and barriers when appropriate.

    The virus presented unprecedented challenges for essential workers, particularly those in healthcare and first responder roles, who faced heightened risk of exposure in their line of duty. In response, many states swiftly adapted their workers’ compensation policies to better address these circumstances. One notable change was the introduction of presumptive eligibility for COVID-19 related claims among certain categories of workers, meaning that if a worker in these designated roles contracted the virus, it was automatically assumed to be work-related, thereby simplifying the claims process and ensuring more timely access to benefits. According to the National Conference of State Legislatures (NCSL), 28 states and Puerto Rico took action to extend workers' compensation coverage to include COVID-19 as a work-related illness. Eleven states enacted legislation creating a presumption of coverage for various types of workers. Utah and Wisconsin limited the coverage to first responders and healthcare workers. Illinois, New Jersey, and Vermont covered all essential workers while California and Wyoming covered all workers. States also used executive branch authority to implement presumption policies for essential workers as part of their COVID-19 emergency responses. However, many of those executive orders expired following the end of the state of emergency in certain states.

    Cyber Insurance
    Cyber insurance generally covers business liability for data breaches involving sensitive customer information and other risks relating to information technology infrastructure and activities. As remote work became the norm for many businesses, the frequency and sophistication of cyberattacks surged, exposing vulnerabilities in digital infrastructure. As a result, insurers began adapting their offerings to meet the evolving needs of clients, expanding coverage to include a broader range of risks associated with remote operations, such as phishing scams, ransomware attacks, and data breaches. Policy terms and conditions were also adjusted to address the unique challenges posed by the pandemic, with insurers providing guidance on cybersecurity best practices and offering support for incident response and recovery efforts. Additionally, greater emphasis was placed on risk assessment and mitigation strategies, with insurers leveraging data analytics and predictive modeling to better understand and price cyber risks. Moreover, with the rise of ransomware attacks targeting healthcare institutions and other critical infrastructure during the pandemic, cyber insurance providers adapted their offerings to include coverage for ransom payments, data recovery costs, and business interruption losses incurred as a result of cyber incidents.

    Additionally, in response to the escalating threat landscape, discussions have also emerged regarding the potential establishment of a federal backstop to mitigate catastrophic cyber-related losses. In 2022, the Treasury Department’s Federal Insurance Office (FIO) published a Request for Information (RFI) to gauge stakeholder appetite regarding such a program. Responses varied, however, FIO did report that broad conceptual support for some type of federal insurance response does exist within the industry. Proponents argue that a federal backstop could enhance the resilience of the insurance industry and provide stability in the face of large-scale cyber events, akin to the role played by federal backstops in other sectors such as terrorism insurance. However, debates surrounding the design and implementation of such a backstop remain ongoing, with considerations including the scope of coverage, eligibility criteria, and the balance between government intervention and market dynamics. As stakeholders continue to assess the feasibility and implications of a federal backstop for cyber insurance, collaboration between policymakers, insurers, and cybersecurity experts remains crucial in developing effective strategies to manage cyber risks in the post-COVID era.

    Personal Injury and Company General Liability Coverage
    CGL policies generally cover bodily injury and property damage sustained by third parties on the premises of the policyholder. During the pandemic, businesses faced a surge in lawsuits alleging negligence in implementing adequate safety measures to prevent the spread of the virus among employees and customers. For instance, grocery stores faced claims from employees alleging they contracted COVID-19 due to inadequate protective measures. Insurance companies were inundated with claims, leading to scrutiny of policy language to determine coverage for pandemic-related incidents. While some policies explicitly excluded coverage for communicable diseases, others faced disputes over interpretation, leading to legal battles over whether COVID-19 incidents fell within the scope of coverage. Moreover, due to widespread business closures, businesses also began filing claims under general liability policies for financial losses.

    Directors and Officers Liability Insurance
    D&O policies protect the personal assets of corporate directors and officers and generally cover claims against directors and officers for breach of fiduciary duties. Whether D&O liability is triggered depends largely on the nature of the claim; the claim must be for damages related to breach of a fiduciary duty and not a claim for bodily injury (which should be covered under by a CGL policy). During the pandemic, D&O insurance emerged as a crucial safeguard amid the unprecedented challenges faced by businesses across various industries. As directors and officers navigated complex decisions concerning workforce management, financial stability, and compliance with rapidly evolving regulations, they encountered heightened scrutiny and legal risks. Lawsuits proliferated against companies and their leadership, alleging mismanagement, negligence, or breaches of fiduciary duty in response to the crisis. Nursing homes and healthcare facilities faced lawsuits alleging negligence by directors and officers in protecting residents and staff from COVID-19, citing failures to implement safety measures like providing personal protective equipment (PPE) and enforcing infection control protocols. Additionally, airlines faced lawsuits related to issues like refund policies, safety protocols, and workforce layoffs, while hospitality companies encountered legal challenges stemming from cancellations, operational shutdowns, and customer safety concerns.

    In this tumultuous environment, directors and officers liability insurance played a pivotal role in mitigating financial risks associated with legal actions, covering defense costs, settlements, and judgments. Insurers responded by reassessing policy terms and exclusions to address the evolving landscape of corporate responsibility amid a global health crisis, underscoring the critical importance of robust risk management strategies for businesses and their leadership.

    Litigation

    Student Lawsuits
    During the spring of 2020, more than 4,000 universities closed their campuses and switched to online learning, affecting at least 25 million students. In response to the shift, various class action lawsuits were filed against colleges and universities across the country by students who argue that schools failed to adequately refund or reimburse them for tuition and other fees. By June 2020, more than 70 universities were facing lawsuits, with students arguing that online-only instruction is less valuable and should cost students less in tuition. The lawsuits primarily alleged breach of contract, with students contending that universities had failed to fulfill their obligations outlined in enrollment agreements to provide a certain standard of education and support. Additionally, many lawsuits also included allegations that universities retained payments for unused services, such as campus amenities, facilities, and resources, constituting claims of unjust enrichment.

    These lawsuits present complex legal questions regarding the nature of the contractual relationship between students and universities, especially in unprecedented circumstances such as a global health crisis. While some universities argued that they made reasonable efforts to adapt to the challenges posed by the pandemic, students countered that these efforts fell short of what was necessary to justify the retention of tuition and fees. The outcomes of these lawsuits varied, with some universities opting to settle to avoid prolonged legal battles, while others defended their positions in court. Despite initial skepticism from courts about the legal basis for such claims, appeals courts reversed several other lower-court dismissals, including cases against New York University and American University. The class-action lawsuit against American University recently reached a preliminary settlement. The U.S. District Court for D.C. granted preliminary approval on January 10th to a $5.439 million class-action settlement between the University and a group of approximately 7,000 eligible students. Additionally, in January 2024, George Washington University settled a lawsuit for $5.4 million with former students who alleged a breach of contract due to the abrupt transition to online-only classes. Many other universities like Johns Hopkins and Columbia have also reached multi-million dollar settlements in similar lawsuits.

    Coronavirus Lawsuits Against China
    During the COVID-19 pandemic, numerous lawsuits were filed in the United States against China and related entities, blaming them for the outbreak. However, these lawsuits faced significant hurdles due to China's immunity under the Foreign Sovereign Immunities Act. In 2022, the U.S. District Court for the Eastern District of Missouri dismissed a prominent lawsuit filed by the state on these grounds. The court ruled that China and its affiliated entities were immune from suit, and none of the exceptions to immunity applied. However, in January 2024, a panel of the U.S. Eighth Circuit Court of Appeals ruled that one claim included in the suit may proceed: an allegation that China hoarded personal protective equipment. In the ruling, Judge David Stras wrote, “Missouri’s overarching theory is that China leveraged the world’s ignorance about Covid-19. One way it did so was by manipulating the worldwide personal-protective-equipment market. Missouri must still prove it, but it has alleged enough to allow the claim to proceed beyond a jurisdictional dismissal on the pleadings.” Aside from this one claim, the panel otherwise agreed with the lower court’s 2022 ruling that dismissed the case. The Chinese government has labeled the lawsuit as "highly absurd" and asserted that it lacks both factual and legal merit. Legal experts have largely dismissed it as a stunt intended to deflect responsibility onto China for the COVID-19 pandemic.

    Resident Lawsuits
    During the height of the COVID-19 pandemic, tensions ran high as residents and lawmakers challenged the constitutionality of their states' governors' stay-at-home orders. Across various states, lawsuits were filed, contesting the restrictions imposed to curb the spread of the virus. Residents argued that these measures infringed upon their fundamental rights, including freedom of movement and assembly. Lawmakers, in turn, questioned the extent of executive power wielded by governors in issuing such orders, advocating for a more balanced approach that considered both public health concerns and individual liberties.

    One major development in this area of litigation occurred in October 2020, when the Supreme Court of Michigan, in a 4-3 majority opinion, ruled that Governor Gretchen Whitmer lacked the authority to extend or declare additional states of emergency in response to the COVID-19 pandemic. Michigan citizens and Republican lawmakers had argued that Governor Whitmer exceeded her constitutional authority when she extended Michigan’s state of emergency and stay at home order beyond the original April 30 deadline. The Court rejected the Governor’s arguments that she derived authority for the extensions from the state’s Emergency Management Act of 1976 and Emergency Powers of the Governor Act (EPGA) of 1945. The Court also held that the EPGA violates the Michigan State Constitution because it illegitimately delegates to the executive branch the plenary police powers of the legislative branch. Additionally, in Wisconsin, the state Supreme Court overturned Governor Tony Evers' extension of the stay-at-home order in May 2020, ruling it unconstitutional due to procedural issues. In Pennsylvania, a federal judge ruled in September 2020 that some of Governor Tom Wolf's lockdown measures were unconstitutional, particularly targeting restrictions on gatherings and business closures. Conversely, in California, multiple lawsuits challenged Governor Gavin Newsom's orders, with courts generally upholding the state's authority to implement necessary restrictions to protect public health. These varying rulings underscored the complexities of navigating a global health emergency within the framework of democratic governance, prompting ongoing debates about the appropriate scope of government intervention in times of crisis.

    Wisconsin Election Lawsuits
    After Wisconsin Governor Tony Evers issued an executive order postponing state in-person voting for the presidential primary election to June because of the coronavirus, the State Supreme Court put the election back on track. Republican lawmakers argued that Evers did not have the authority to unilaterally postpone the election and accused the Governor of “unconstitutional overreach” The state Supreme Court agreed. In a separate lawsuit brought by the Wisconsin Republican Party, the U.S. Supreme Court voted 5-4 to overturn a federal judge’s decision to extend the time for absentee voting by a week. The joint result of these legal actions meant that Wisconsin voters had to vote in-person for the April 7 primary election, despite the state stay-at-home order and national social distancing guidelines. On election day, the city of Milwaukee consolidated its 180 polling places to just 5 locations, leaving voters waiting in long lines stretching across multiple blocks. Many poll workers quit due to fears of virus exposure, leaving nearly 300 of the state’s National Guard troops to replace those volunteers and help run the polling places. At least 52 new cases of coronavirus in Wisconsin were linked to in-person voting at the state primary election.

    Business Interruption Claims
    During the pandemic, government-mandated closures and operational restrictions affected businesses around the world. In response, a wave of litigation has emerged as policyholders seek coverage under their business interruption insurance policies for the resulting financial losses. These lawsuits have spanned various sectors, from restaurants and retail establishments to manufacturing facilities and professional services firms.

    According to the NAIC, approximately 17% of the commercial property insurance policies issued prior to the pandemic did not include an exclusion for losses caused by virus, communicable disease, or pandemic. Consequently, policyholders with broad policy wordings and strong claims are now pursuing coverage, leveraging the ambiguity present in the policy language. These legal battles primarily revolve around the interpretation of policy language and the extent of coverage offered by business interruption insurance. Courts have grappled with questions regarding the requirement of physical loss or damage, with plaintiffs arguing that the presence of the virus constitutes such harm, while insurers contend that traditional property damage is necessary to trigger coverage. APCIA senior vice president and general counsel Claire Howard expressed insurers’ stance that property policies are only intended to cover “actual physical loss”, such as fire or tornado. “These policies are not intended to cover diseases or pandemic-related losses,” Howard said. “In the vast majority of cases, insurers did not price policies to include such coverage, and policyholders did not pay for it.” In New York alone, APCIA has estimated that business interruption losses would range from US$5.8 billion to US$21.5 billion per month for businesses with under 250 employees. This is at least 18 times the US$300 million total monthly premiums written for commercial property in the state, according to an APCIA and National Association of Mutual Insurance Companies Amici brief.

    The complexity of this legal landscape has been further compounded by the sheer volume of litigation and the lack of uniformity in judicial rulings across various jurisdictions. According to the University of Pennsylvania Carey Law School’s COVID Coverage Litigation Tracker, over 2,300 lawsuits have been filed since March 2020 in state and federal courts. About 73% of insurers' motions to dismiss decided by state courts have been granted, and about 93% in federal court, according to the tracker. However, a recent article describes how momentum may be shifting in favor of policyholders. The shift comes in part as a growing number of state appellate courts are recognizing that many previous COVID-19 BI rulings actually represent a deviation from the “well-established precedent” that damage is tangible and subject to coverage even when the “property is not structurally altered, the principal consequence is a loss of functionality and neither the cause of the damage nor the damage itself is visible to the naked eye”. Courts are now considering pre-pandemic holdings that losses from fumes, bacteria, and other causes of non-structural damage are covered, and allowing more COVID-related business interruption claims to proceed toward trial. A significant milestone signaling this shift occurred in September 2022, as the Vermont Supreme Court became the first state high court to establish that well-supported claims of "direct physical loss or damage" to property from COVID-19 could potentially justify coverage for business interruption losses. The decision followed a growing number of state appellate court decisions, including California, Louisiana, and Alaska, favoring policyholders on this critical issue.

    Another emerging trend related to COVID-19 business interruption losses involves increased litigation between insurers and reinsurers. Reinsurers have become implicated in disputes over the extent of their liability for business interruption losses stemming from the pandemic. As primary insurers face mounting claims from policyholders seeking coverage for their financial losses, those insurers have begun turning to their reinsurers to share the burden of indemnification. Central to these conflicts is the interpretation of contractual language where reinsurers may argue that their agreements contain exclusions or limitations that absolve them of liability for pandemic-related losses. Conversely, insurers may contend that their reinsurance contracts provide broader coverage or lack explicit exclusions for such events. Disputes also emerge over the causation and triggering events for coverage, with insurers arguing that the presence of the virus constitutes physical loss or damage, while reinsurers insist that tangible structural harm is necessary. The resolution of these disputes can have significant implications for the insurance industry as a whole, impacting the availability and affordability of coverage for future catastrophic events. The legal landscape remains fluid, with ongoing litigation shaping the interpretation of insurance contracts and setting precedents for future claims arising from unforeseen events.

    Unipolsai Assicurazioni SpA (substituted as claimant for UnipolRe Designated Activity Co., Ireland) v Covea Insurance Plc (2024)
    The UK Commercial Court recently delivered a landmark ruling in favor of insurers Covéa and Markel concerning a non-damage business interruption case stemming from the pandemic. The appeals were heard before the same judge on consecutive days, and a single judgement was issued by Justice Foxton given the “substantial overlap” between the issues. To date the majority of litigation has involved policyholders and insurers, however, disputes over reinsurance coverage are becoming increasingly common. In this case, the dispute involved the insurers and their respective reinsurers, General Reinsurance AG for Markel and UnipolRe Designated Activity Company for Covéa. This decision holds significant implications, potentially establishing a precedent for similar pandemic-related business interruption lawsuits.

    The cases involved claims by parties seeking compensation under property catastrophe excess of loss reinsurance policies related to business interruption losses due to the pandemic. These policies provided coverage to businesses operating nurseries and childcare facilities. The closure of schools and childcare centers prompted the businesses to file claims under these policies. The parties seeking indemnity argued that the losses were directly caused by the pandemic, constituting a catastrophe as per the terms of the reinsurance agreements. Central to the judgement was the interpretation of certain reinsurance contract provisions, specifically the definition of “catastrophe” and the application of the hours clause. The Court ultimately ruled in favor of the insurers, permitting them to recover their losses under the reinsurance contracts. The case was decided in part on the court’s ruling that “catastrophe” is not limited to those which cause or are capable of causing physical damage. Additionally, the Court rejected the argument that “a catastrophe was necessarily sudden in onset or short in duration, or that it was violent.” The court's ruling represents a broader interpretation of these policy terms, potentially establishing a precedent for recognizing a wider array of business interruption claims. This ruling has the potential to greatly impact pending COVID-19 reinsurance claims and, consequently, the broader reinsurance market.

    Huntington Ingalls Industries V. Ace American Ins. Co. (2022)
    The Vermont Supreme Court made a landmark decision in COVID-19-related business interruption litigation, becoming the first state high court to rule in favor of policyholders. The lawsuit was filed by Huntington Ingalls Industries, a major military shipbuilding company based in Newport News, Virginia, and its captive, Huntington Ingalls Industries Risk Management LLC, headquartered in Burlington, Vermont, against their reinsurers, including Chubb Ltd. unit Ace American and several others. The court found that the complaint sufficiently demonstrated that COVID-19 caused direct physical damage to the insured’s shipbuilding facilities. The virus’s presence at the facilities and its adherence to surfaces were deemed to have led to detrimental physical effects that altered and impaired the functioning of the property. Consequently, the property could no longer serve its intended purpose, necessitating physical alterations such as installing barriers to address these effects. The court concluded that the statements in the complaint provided enough evidence to support the claim that the virus physically altered the property, leading to the reinstatement of the litigation and remanding the case for further proceedings.

    Consolidated Restaurant Operations, Inc. v. Westport Ins. Corp. (2022)
    The lawsuit involves Consolidated Restaurant Operations (CRO), a company managing numerous restaurants, and Westport Insurance Corporation (Westport). CRO held an "all-risk" commercial property insurance policy with Westport, covering "all risks of direct physical loss or damage to insured property." When the COVID-19 pandemic forced CRO to suspend or significantly reduce its operations due to virus presence in its restaurants and government-imposed restrictions on nonessential businesses, CRO sought coverage for resulting revenue loss. Westport refused coverage, arguing that the coronavirus didn't cause "direct physical loss or damage" to CRO's properties. Consequently, CRO filed a lawsuit seeking a declaration of Westport's policy obligations and damages for breach of contract.

    The Supreme Court of New York dismissed the complaint, ruling that the policy didn't encompass CRO's purported losses. The Appellate Division upheld this decision, interpreting "direct physical loss or damage" to necessitate a tangible alteration of the property, which CRO failed to prove. Subsequently, the case was brought to the New York Court of Appeals. On February 15, 2024, the court rendered its decision. The court agreed that “direct physical loss or damage” requires a substantial alternation or complete and ongoing disposition of insured property. It was determined that the presence of the virus in the restaurants and the resulting interruption of in-person dining didn’t satisfy this requirement. As such, the court affirmed the dismissal of the complaint.

    K.C. Hopps, LTD v. Cincinnati Ins. Co. (2021)
    K.C. Hopps, a company managing various entertainment establishments in Kansas City, faced significant financial losses due to COVID-19 pandemic restrictions in 2020, estimating a loss of $2 million in business income. Seeking reimbursement, K.C. Hopps filed a claim under its all-risk insurance policy with Cincinnati, which was denied. K.C. Hopps then sued Cincinnati, alleging breach of contract for refusing to honor the claim. A distinguishing aspect of this lawsuit was K.C. Hopps' assertion that COVID-19 had physically damaged its properties by altering air particles and surfaces. Cincinnati sought summary judgment, but the district court found a genuine dispute regarding whether K.C. Hopps had experienced physical loss or damage.

    The case proceeded to a jury trial (the first jury trial in a COVID-19 business interruption coverage lawsuit) where both parties moved for judgment as a matter of law at the close of evidence. The district court denied both motions, and the jury ruled in favor of Cincinnati. Following the verdict, K.C. Hopps renewed its motion for judgment as a matter of law and sought a new trial, both of which were denied by the district court. K.C. Hopps appealed the decision.

    The appeals court reviewed the denial of judgment as a matter of law de novo, using the same standards as the district court. K.C. Hopps argued entitlement to coverage under two policy provisions: the General Coverage provision and the Business Income provision. These provisions protected K.C. Hopps from direct loss, defined as “accidental physical loss or accidental physical damage.” The court cited previous cases to establish the legal standard for what constitutes a "physical loss" under the insurance policy. It emphasized that the loss or damage must involve some physical alteration, contamination, or destruction of property. Additionally, under the policy terms, the direct physical loss or damage must be responsible for the loss of income. The court clarified that while contamination could be considered a physical loss, the COVID-19 virus itself does not cause the type of physical harm required to trigger coverage under the policy. Furthermore, the court argued that any contamination wasn’t the cause of the lost business income. The shutdown orders imposed by the government, rather than the presence of COVID-19 particles, were the primary reason for K.C. Hopps’ business interruption. Therefore, the court concluded that K.C. Hopps' claim did not meet the standard for physical loss under the insurance policy, and the district court's decision to deny judgment as a matter of law was upheld.

    Tambellini v. Erie Insurance Exchange (2020)
    Joseph Tambellini, owner of the Tambellini Restaurant in Pittsburgh, Pennsylvania, along with HTR Restaurants Inc., and several other businesses filed suit against their insurance company, Erie Insurance Exchange seeking declaratory, compensatory, and injunctive relief with respect to coverage for losses caused by the COVID-19 pandemic and the government orders connected to it. In full force and effect is an Erie Insurance Exchange “Ultra Plus Commercial General Liability Policy” (“Erie Policy”) that includes coverage for business and business income losses. The Plaintiff asserts that the Erie policy does not exclude losses caused by the coronavirus pandemic and is entitled to receive coverage for losses incurred by the restaurant as a result of the pandemic. Such losses include government mandated business closures and the forced furlough of restaurant employees. Tambellini argues that the coronavirus is susceptible to person to person, person to property, and property to person transmission and contamination. Thus, the plaintiff argues that the COVID-19 pandemic has adversely affected the operations of his restaurant by causing damage to the property and its occupants resulting in related losses which are covered under its Erie insurance policy.

    Given the factual and legal overlap between various claims filed in courts across Pennsylvania, the businesses moved for all state-wide litigation to be coordinated in Allegheny County for all pre-trial and trial purposes under Rule of Civil Procedure 213.1. Erie appealed to the Superior Court, which partially upheld and partially reversed the lower court’s decision. The Superior Court determined that the trial court exceeded the authority of Rule 213.1 by ordering the coordination of similar actions against Erie that had not yet been filed. The Superior Court further held that the businesses did have the right to initiate the motion for coordination of already filed lawsuits under Rule 213.1. Following the parties’ cross-appeals, the Supreme Court of Pennsylvania granted review of both holdings. On December 8, 2023, the Supreme Court of Pennsylvania rendered its decision. The Supreme Court agreed with the Superior Court that the trial court lacked authority to coordinate actions that had not yet been filed. Additionally, the Supreme Court found that Erie had waived the opportunity to argue against the businesses seeking coordination by failing to raise it as an issue in trial court. Therefore, the Supreme Court affirmed the Superior Court’s order.

    Simon Wiesenthal Center, Inc. et al v. Chubb Group (2020)
    A Los Angeles nonprofit group that advocates for human rights and combats anti-Semitism sued Chubb Ltd. in the U.S. District Court for the Central District of California, asserting that it is entitled to business interruption coverage under its August 2019 Chubb policy. The Simon Wiesenthal Center is a Jewish human rights organization that supports Holocaust research and is dedicated to Holocaust and Nazi-death camp survivor, Simon Wiesenthal. The Center was closed on March 19th by California stay-at-home orders and forced to cancel several events and fundraisers due to COVID-19. The Center alleges that its business interruption policy should cover its lost profits because its policy covers “physical” property loss and damage. The center argues that this requirement is met since COVID-19 can attach to surfaces and because viruses are not listed on its policy as “pollutants” that are excluded from coverage. On June 1, 2020, the policyholder filed a notice of dismissal and the court entered an order dismissing the action without prejudice.

    The Financial Conduct Authority v. Arch and Others (U.K. 2020)
    Many policyholders suffered significant losses to their businesses affected by COVID-19. These losses resulted in a large number of claims arising under business interruption insurance policies. Most policies focus on property damage and uncertainty existed as to whether these policies would cover economic losses resulting from the pandemic. On June 9, 2020, the Financial Conduct Authority (FCA) initiated proceedings seeking a judicial determination on the scope and meaning of sample insurance wordings of Business Interruption policy coverage. The FCA brought the test case in the High Court of Justice in London against eight insurer defendants —Arch Insurance (UK) Limited, Argenta Syndicate Management Limited, Ecclesiastical Insurance Office Plc, Hiscox Insurance Company Limited, MS Amlin Underwriting Limited, QBE Limited, Royal & Sun Alliance Insurance Plc, and Zurich Insurance Plc — representing the interests of medium sized business policyholders. The outcome of the case affects over 700 insurance policies, 60 insurers, and 370,000 policyholders. The goal of the case was synthesized by Christopher Woolard, Chief Interim Chief Executive of the FCA, who explained that, “Coronavirus is causing substantial loss and distress to businesses and many are under immense financial strain to stay afloat. Our aim throughout this court action has been to get clarity for as wide a range of parties as possible, as quickly as possible.”

    The arguments in this case were heard on an expedited basis and the Court considered 21 policy wordings from the eight Defendant insurers. Although the High Court reached different conclusions for each of the differently worded policies, on September 15, 2020, the Court held in the general favor of the FCA and found that most disease clauses in the sample business insurance policies do provide coverage for policyholders. Following appeals by both the FCA and the insurers regarding the High Court’s decision, the case was expedited to the Supreme Court of the United Kingdom to promptly resolve the consequential legal questions central to this case. In January 2021, the Supreme Court delivered its highly anticipated judgment, largely upholding the High Court's decision and providing clarity on the issue. The Supreme Court addressed the following issues raised by the appeals:
    • Disease Clauses: The Court interpreted disease clauses as covering business interruption losses resulting from COVID-19 occurrences within the specified geographical radius.
    • Prevention of Access and Hybrid Clauses: The Court broadened the interpretation of “restrictions imposed” to include an instruction given by a public authority that is in “mandatory and clear terms and indicates that compliance is required without recourse to legal powers.” The Court also broadened the interpretation of the “inability to use” requirement.
    • Causation: The Court ruled that business interruption losses resulting from public health measures were caused by cases of COVID-19 occurring within the specified radius, rejecting the “but for” test of causation.
    • Trends Clauses: These clauses are used to quantify BI losses by considering what the business's performance would have been if the insured peril had not occurred. Insurers argued they were not liable for losses that would have happened regardless of the insured perils due to the broader effects of the COVID-19 pandemic. However, the Supreme Court disagreed. They interpreted trends clauses to mean that adjustments should only be made for circumstances unrelated to the insured peril, not those inextricably linked to it.
    • Pre-Trigger Losses: The High Court initially allowed adjustments under trends clauses to account for business downturn due to COVID-19 before the insured peril was triggered. However, the Supreme Court rejected this. They stated that pre-trigger losses caused by the pandemic should not be assumed to continue during the operation of the insured peril. Adjustments should only be made for circumstances unrelated to COVID-19.
    • Status of Orient-Express: The Supreme Court overruled the decision in the Orient-Express case, where the business interruption was attributed to two concurrent causes, neither of which was the sole cause of the loss. The Supreme Court found that the treatment of the trends clause in the previous proceedings was incorrect. They emphasized the exclusion from loss assessment of circumstances with the same underlying or originating cause as the damage. Overall, the UK Supreme Court ruling was seen as a victory for policyholders, as it affirmed that many business interruption insurance policies did indeed cover losses resulting from the pandemic and government-mandated closures, subject to the specific policy wording.

    Future Outlook

    The COVID-19 pandemic has had profound effects on global politics, economies, and societies. It has exposed vulnerabilities in healthcare systems, highlighted inequalities, and reshaped work and social norms. The insurance industry continues to grapple with the financial fallout of the pandemic, with estimates of losses reaching billions of dollars. Legal disputes and litigation related to insurance coverage and liability are expected to persist for years to come. As the world navigates the ongoing challenges posed by COVID-19, the full extent of its long-term effects remains to be seen. Adaptive responses, technological innovations, and international cooperation will play crucial roles in shaping the post-pandemic future.

    In the News

    2024

    • Ruling over Covid insurance claims a win for thousands of businesses – lawyers - Tom Pilgrim, pa media (09/06/2024)
      Insurers’ failed appeals against a “landmark” ruling over a £16 million Covid-19 pandemic-losses claim brought by London’s ExCel centre could allow thousands of other businesses to pursue payouts, lawyers have said. On Friday, the Court of Appeal rejected a bid by insurance firms to reverse a June 2023 High Court decision over insurance policies and claims for business interruption losses linked to the disease outbreak.
    • California’s Supreme Court clarifies law on COVID-19 and property insurance claims - Parisa Saleki, FMG Law (05/24/2024)
      On May 23, 2024, The Supreme Court of California, upon request of the United States Court of Appeals for the Ninth Circuit, issued a ruling to clarify the law on whether the actual or potential presence of the COVID-19 virus on an insured’s premises constitutes ‘direct physical loss or damage to property’ for purposes of coverage under a commercial property insurance policy.
    • Supreme Court denies California’s appeal for immunity for COVID-19 deaths at San Quentin prison - Christopher Weber, The Associated Press (05/13/2024)
      The U.S. Supreme Court on Monday denied an appeal from California corrections officials who sought immunity from lawsuits claiming they acted with deliberate indifference when they caused a deadly COVID-19 outbreak at one of the world’s most famous prisons four years ago. The justices turned down the appeal without comment or dissent.
    • 5th Circuit: Chubb Must Cover SXSW in Suit Over Cancelled 2020 Festival - Ezra Amacher, Insurance Journal (03/26/2024)
      The 5th Circuit Court of Appeals ruled last week that Chubb must cover restitution claims paid to ticket holders of the 2020 South by Southwest film festival cancelled due to COVID-19. A three-judge panel reversed a summary judgment in favor of Federal Insurance Company (Chubb), finding that its policy exclusions did not preclude coverage to SXSW Ltd. over a class action lawsuit brought by festival pass holders.
    • Geico Won't Face Class-Action Claims It Overcharged Drivers During Pandemic - Jonathan Stempel, Reuters (03/12/2024)
      Geico, the car insurer owned by Warren Buffett's Berkshire Hathaway, will not face class-action claims as it defends against a lawsuit alleging it overcharged policyholders early in the COVID-19 pandemic, a federal judge ruled on Tuesday. U.S. District Judge Sharon Johnson Coleman in Chicago said policyholders in Illinois could not sue as a group because questions about calculating damages for individual drivers would "inevitably overwhelm" questions common to the proposed class.
    • New Jersey Supreme Court rules against Ocean casino in COVID business interruption case - Wayne Parry, The Associated Press (01/24/2024)
      New Jersey’s Supreme Court ruled Wednesday that an Atlantic City casino is not entitled to payouts from business interruption insurance for losses during the COVID-19 outbreak, determining that the presence of the virus did not constitute the kind of “direct physical loss or damage” required for such a payout.

    2023

    • State settles another lawsuit over COVID death in N.M. veterans' home - Daniel J. Chacón, The Santa Fe New Mexican (10/09/2023)
      The state has settled another wrongful death lawsuit involving a resident of the New Mexico State Veterans' Home who died in 2020 after contracting COVID-19.
    • New Jersey Supreme Court to rule on pandemic-related insurance exclusions - Wayne Parry, The Associated Press (09/27/2023)
      New Jersey’s Supreme Court is considering whether an Atlantic City casino can get payouts from business interruption insurance for losses during the COVID-19 outbreak, potentially providing guidance for policyholders nationwide regarding the scope of coverage for pandemic-related losses.
    • Arizonans can now receive workers comp benefits for getting Covid-19 on the job - Gabrielle Parish, KVOA (09/23/2023)
      In a groundbreaking development, Arizonans can now apply for worker's compensation if they contract COVID-19 while on the job. This landmark decision stems from a widow's determined fight to secure worker's compensation following her husband's tragic demise due to COVID-19.
    • Lawsuit against Fair Acres over COVID death ends in confidential settlement - Alex Rose, Delco Daily Times (08/26/2023)
      Family members of a Fair Acres Geriatric Center resident who died of pneumonia associated with COVID-19 have entered into a confidential settlement agreement with Delaware County and the facility, according to a recent order issued in the case.
    • Appeals panel says Pritzker order may shield nursing homes from negligence lawsuits during Covid - Scott Holland, Cook County Record (08/21/2023)
      A state appeals panel has determined one of Gov. JB Pritzker’s 2020 executive orders can shield nursing homes from lawsuits bringing “ordinary negligence” claim from incidents occurring during the time the order was in effect.
    • California Employers Will Not Be Liable for COVID-19 Infections Contracted by Workers’ Household Members - Perkins Coie (07/19/2023)
      The California Supreme Court unanimously ruled in Kuciemba v. Victory Woodworks, Inc. on July 6, 2023, that California employers cannot be held liable by their workers’ household members when workers contract COVID-19 in the workplace and spread the disease to their household members. This decision prevents millions of potential plaintiffs from bringing claims against California employers.
    • Mass. Hospital Asks 1st Circ. To Revive COVID Coverage Bid - Ganesh Setty, Law360 (07/13/2023)
      A Massachusetts hospital urged the First Circuit to reverse the dismissal of its suit against Continental Casualty Co. seeking coverage for its COVID-19-related losses, arguing it alleged in "painstaking detail" how the virus physically altered its property and how the hospital's remediation efforts went beyond "simple cleaning."
    • University of Delaware agrees to settle class-action suit over COVID campus shutdown - Randall Chase, The Associated Press (06/14/2023)
      The University of Delaware has agreed to pay $6.3 million to settle a lawsuit over its campus shutdown in 2020 and the halting of in-person classes because of the coronavirus pandemic. According to court papers that were filed this month and signed by the plaintiffs and university president Dennis Assanis, some 21,000 current and former students could receive cash reimbursements.
    • India denies massive data breach involving Covid vaccine website - Arpan Rai, The Independent (06/12/2023)
      India on Monday sought to allay fears that the personal data of hundreds of millions of citizens who signed up on a government portal to book their Covid-19 vaccines had been breached, after reports that a Telegram bot was distributing the information online.
    • Nevada’s highest court hears insurance dispute from COVID-19 lockdowns - Katelyn Newberg, Las Vegas Review-Journal (06/05/2023)
      The Nevada Supreme Court heard oral arguments Monday from an insurance company claiming it should not have to provide coverage to a Strip open-air mall that lost business due to the COVID-19 lockdowns in 2020.
    • Louisiana high court rules against policyholders on COVID - Judy Greenwald, Business Insurance (03/17/2023)
      The Louisiana Supreme Court on Friday overturned a rare state appeals court ruling in policyholders’ favor and ruled in a divided opinion that policyholders are not entitled to COVID-19-related business interruption coverage.
    • Legislative panel OKs COVID-19 disability bill for Chicago’s first responders - Jeremy Gorner, Chicago Tribune (03/09/2023)
      A measure that would make it easier for Chicago’s first responders to acquire full disability benefits if they were sickened by COVID-19 gained traction Thursday when it passed through a state legislative committee.
    • Arkansas Tyson workers sue over lack of COVID protections - Dee-Ann Durbin, The Associated Press (03/06/2023)
      Thirty-four Tyson Foods employees, former employees and family members filed a lawsuit against the company Monday, saying it failed to take appropriate precautions at its meat-packing plants during the early days of the COVID pandemic.
    • Colorado businesses seek millions from insurance companies for COVID-related losses - Judith Kohler, The Denver Post (03/03/2023)
      Huge financial losses are among the lingering effects of the COVID-19 pandemic, and Colorado businesses and public institutions are among those suing their insurance companies to get some relief. However, experts say the courts might not be a cure.
    • Geico can't end class action claiming its Covid savings plan didn't cut rates enough - Scott Holland, Cook County Record (02/09/2023)
      A federal judge rejected Geico’s attempts to put the brakes on a class action complaint accusing the insurer of offering insufficient recompense during the early days of Covid-19.

       

    • Third Circuit agrees that a lack of 'imminent danger' dooms food workers' suit over COVID-19 conditions - Nicholas Malfitano, Pennsylvania Record (02/07/2023)

      In a matter of first impression, the U.S. Court of Appeals for the Third Circuit has unanimously upheld a lower court dismissal of a lawsuit from workers at a meat processing plant against both the Department of Labor and Occupational Safety and Health Administration – litigation which alleged the agencies refused to enforce COVID-19 pandemic protocols in spite of receiving complaints about the workplace situation, due to OSHA finding no “imminent danger” present.

       

    • Insurers Avoid Picking Up Businesses’ Covid-19 Pandemic Costs - Richard Vanderford, The Wall Street Journal (02/03/2023)
      Businesses have long relied on insurance to cover losses from unexpected disruptions. But they have faced an uphill battle in trying to get carriers to pay out on one of the biggest ever: pandemic shutdowns.

       

    • Connecticut Supreme Court rules for insurers in COVID cases - Judy Greenwald, Business Insurance (01/30/2023)
      The Connecticut Supreme Court on Friday joined other state supreme courts when it unanimously affirmed lower court rulings against policyholders in two COVID-19-related business interruption cases.

       

    • Study: Long COVID kept people out of work for months - Jacob Knutson, Axios (01/24/2023)
      People experiencing long COVID were more likely to be unable to return to work for weeks because of their symptoms or continued to receive medical treatment for their infection after they returned to work, according to a study published on Tuesday by the state’s largest workers’ compensation insurer.

       

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    Additional Items

    By far and away the most well rounded and useful Cat-focused industry conference out there. Perfect for all levels within the industry. From the conference content, the presenters and the attendees, this conference is a can’t miss for those interested in expanding their knowledge and learning more about cat related insurance and reinsurance modeling topics Nick DiMuzio, Everest

    "Fantastic, enriching conference - brilliantly planned and run, illuminating talks and excellent opportunities for networking across multiple areas of catastrophic risk.” Gary Ackerman, University at Albany

    “From a treaty underwriter's point of view, RAA presented relevant topics related to today's macro events. Scientific presentations provided insight that I can incorporate in underwriting and share with my clients.” Eric B. Silberman, Munich Re

    "Great conference with some of the biggest names in the business presenting their work. What more could you ask for?” Ron Nash, Nash Consulting

    “A perfect introduction to the world of reinsurance. Relevant topics, great speakers and the opportunity to network with industry peers makes this a must go event.”
    Tom Barrett, Everest Re

    Demystifying Reinsurance was an excellent tool to clearly understand and break down the basics. Very good class and recommend it for beginners and even as a refresher course for the intermediate student.”
    Chenessia West, TransRe

    “Re Basics is the ideal opportunity whether an industry professional or student of insurance to understand the in and outs of reinsurance while being able to network with persons spread across the whole industry.”
    Darius Zuill, Bermuda Monetary Authority

    “This has been the best reinsurance seminar that I have been to! Whether a reinsurance seasoned vet or new to the field, this is an engaging seminar that addressed specific issues of the reinsurance market.”
    Michelle Thimm, Church Mutual Insurance 

    “Re Underwriting provided a comprehensive and interesting overview of underwriting in the current market with a major (and interesting) focus on trends. Very useful for underwriting and non-underwriting alike.”
    DeVika Bourne, PartnerRe

    “Very informative experience, and a great way to keep up to date on current underwriting events and trends.”
    Steven Whalen, Aspen Re

    “Time well spent in learning the updated underwriting business and networking!”
    Christine Chen,  Everest Re 

    “The panels and presentations were thought provoking and fascinating as numerous topics were covered affecting the industry. I’m leaving the conference with a greater insight of the future market.”
    Brittany de Frias, AXIS Capital 

     

    “RAA Re Finance was the first RAA seminar I attended, and I was thoroughly impressed with the speakers and content. I learned a great deal from the presentations and intend to bring some new ideas back to my company and share with the team!”
    Taylor Robinson, ICW Group

    “Fantastic slate of instructors who thoughtfully walked us through financial reporting and other aspects of reinsurance finance. They used terminology that non finance people (lawyers) could understand. Really great program.”
    Steven Bazil, The Bazil Group

    “If you are in Reinsurance Accounting/Finance, you need to take this course to help you with your job.”
    Frank Borawski, Markel  

    “The speakers were excellent! There is something to be said about a person, and in this case a group of people, who can take time away from their busy schedules and explain to everyone something they feel passionate about in a manner that's understandable. My only complaint is that I wish we had more time with them.”
    Jessica Mieles, Sompo International

    “The RAA ReContracts is the most comprehensive reinsurance contract wording training available in the U.S. market.”
    David Kragseth, Guy Carpenter   

    “The course was very helpful in addressing different viewpoints and important things to consider in contract design and review.”
    Andy Martin, AmericanAg 

    “The RAA contract course was very informative and interesting. It covered a wide range of Reinsurance Contracts Types. In my Reinsurance Career, I have had the opportunity to work on a limited type of contracts, so I learned a lot.”
    Vivian Castro, Arch Insurance Company 

    “The RAA Contracts course provides the opportunity to engage with relevant topics, taught by industry experts, in both seminar and small group environments. The course material and industry experts provide an understanding on a wide range of subjects.” 
    Kevin English, LMRe

    “Participation in Re Claims should be mandatory for all P&C reinsurance underwriters. It’s truly an eye-opener, providing an in-depth look from a claims manager’s perspective on what happens to the business that we underwrite. There are lots of do’s and don’ts to pay attention to. Re Claims answers all the hard questions."  Michael Delacruz, China Re P&C

    “I absolutely love this program. I learned so many new things. Reinsurance from the industry’s top executives, interactive activities, interesting panels, and innovating presentations makes for an intriguing few days. Well worth the time and money.” Chenessia West, TransRe

    “As a reinsurance attorney I find Re Claims highly valuable to stay abreast of emerging issues. Also, being walked through practical case studies is extremely helpful in creating a thorough understanding of how contracts work.” Steven Bazil, The Bazil Group

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