Insurance Coverage in the Age of COVID-19
On March 11, 2020, the World Health Organization declared COVID-19 a pandemic. To slow the speed of transmission and “flatten the curve,” numerous countries have issued “stay-at-home” or “shelter-in-place” orders, travel restrictions, quarantines and other similar measures. The United States now leads in the total number of reported cases worldwide. In response, President Trump has recommended continuing social distancing until April 30 and many states and counties have issued stay at home orders. Generally, these orders require people to stay at home except to meet essential needs and close non-essential businesses such as theaters, beauty salons, and bookstores. Many restaurants are also forced to close their dining rooms, but may offer take-away or delivery services. Companies whose workforce can continue operations remotely have largely shifted to working from home. Major events such as South by Southwest, CERAWeek, March Madness, and the Olympics have been cancelled or postponed. Unsurprisingly, these measures have caused businesses in almost every sector and every location to sustain lost income causing business owners and their insurers to question the applicability of business interruption insurance and other coverage to these unprecedented circumstances.
This article will discuss the policy provisions that are likely implicated by a COVID-19 related business loss, including business interruption coverage. Because this is a novel virus and unprecedented pandemic, it remains to be seen whether and, if so, to what extent, there may be insurance coverage for COVID-19 related losses. Where possible, we have drawn from historical examples to offer some guidance as to how claims related to COVID-19 may be adjudicated. Ultimately, the outcome will depend on the particular facts and language in the insurance policies in play and how judges and juries apply the specific language of each policy to the particular facts in each case. It remains to be seen whether legislative action will mandate certain coverage, but at least four state legislatures have proposed such legislation.
I. All Risk or Commercial Property Insurance
All-risk and commercial property insurance policies provide businesses with property coverage against perils such as fire, theft, and natural disaster. Many of these policies also provide business interruption coverage. To trigger coverage, the insured typically must suffer a “direct physical loss or damage” to the covered premises. Insureds will likely face hurdles in showing that a COVID-19 related loss resulted “from a direct physical loss or damage” to property. However, specific policy endorsements may provide avenues for coverage, including but not limited to communicable disease coverage, crisis management coverage, and civil or military authority coverage. Policy exclusions may also limit coverage, including exclusions for pollutants or contaminants, or for viruses.
Direct Physical Loss
The insuring provision in most property insurance policies require “risk of” or a “direct physical loss or damage” to the covered property resulting from a “covered cause of loss.” Thus, to trigger coverage, including under an endorsement to the policy such as for business interruption, the insured must first prove that there was a “direct physical loss or damage” to the property resulting in a covered loss. Those policies that cover a “risk” of “direct physical loss or damage” may be interpreted more broadly than those that do not. Regardless, to be entitled to coverage, the insured will have to show some type of physical loss or damage to property. In the case of a microscopic virus, this is likely to be difficult. Where the insured suffers a loss due to prevention of the spread of the virus among persons, as opposed to preventing “risk” of “damage” to property, it may be even harder.
The most likely argument insureds will make for coverage will be that the COVID-19 virus causes physical loss or damage by being present on workplace surfaces, which is the cause of the claimed loss. The CDC has said that “it may be possible that a person can get COVID-19 by touching a surface or object that has the virus on it and then touching their own mouth, nose, or possibly their eyes, but this is not thought to be the main way the virus spreads.” i There is uncertainty regarding how long the virus can live on a surface, but authorities believe it is at least for a matter of days. Even if this may be sufficient to trigger coverage, questions remain as to the scope of a covered loss. For example, would a property loss claim be limited to the cost of cleaning work surfaces to remove the virus and a business interruption claim be limited to the time it takes to decontaminate the workplace?
Insurers will counter that “direct physical loss or damage” to property requires a tangible property loss, such as one caused by fire or the contamination of goods by a bacteria, but would not include preventative measures to control the spread of disease.
Importantly, if a court were to agree that there was no “direct loss or property damage,” then it is unlikely there will be coverage for the loss. This is because the policy endorsements, including those discussed below, likely come into play only if there is a covered loss—meaning a direct physical loss or damage to property resulting from a “covered cause of loss.”
While this determination will depend on the precise policy language, case law provides an indication of how such policies may be interpreted.
Some courts have concluded that intangible contamination, such as that resulting from asbestos or E. Coli, can result in a “direct physical loss” by causing the premises to be uninhabitable. For instance, inMotorists Mut. Ins. Co. v. Hardinger,ii a homeowner’s well was contaminated with E. Coli. The property owners claimed that contamination made the home uninhabitable. The insurance company argued that the contamination did not constitute a “direct physical loss or risk of a direct physical loss.”iii The Third Circuit Court of Appeals denied summary judgment finding there was a fact issue as to whether the bacteria met that standard to constitute direct physical loss to the property.iv In so holding, the court looked to case law related to asbestos contamination.v In discussing asbestos contamination, the Third Circuit Court of Appeals held that:
[i]n the case of asbestos, . . . the ‘proper standard for “physical loss or damage” to a structure’ [is whether] an actual release of asbestos fibers from asbestos containing materials has resulted in contamination of the property such that its function is nearly eliminated or destroyed, or the structure is made useless or uninhabitable, or if there exists an imminent threat of the release of a quantity of asbestos fibers that would cause such loss of utility.vi
In analogous cases involving toxic substances, courts have found direct physical loss. For instance, in TravCo Ins. Co. v. Ward,vii the court held that dry wall that emitted sulfide gasses and other toxic chemicals constituted a “direct physical loss” viii but denied coverage under exclusions for latent defects,ix faulty materials,x corrosion,xi and pollution.xii Similarly, in Gregory Packaging, Inc. v. Travelers Prop. Cas. Co. of Am.,xiii a Georgia court held that the property sustained a direct physical loss because of an ammonia leak. The court noted that “[a]lthough the Georgia Supreme Court has not construed the terms at issue here, the Court of Appeals of Georgia has held that direct physical loss or damage occurs when there is ‘an actual change in insured property then in a satisfactory state, occasioned by accident or other fortuitous event directly upon the property causing it to become unsatisfactory for future use or requiring that repairs be made to make it so.’” xiv The court held that there was a direct physical loss because “there is no genuine dispute that the ammonia release physically changed the facility's condition to an unsatisfactory state needing repair." xv
However, loss of use of premises because of fear of contamination or to prevent contamination may not rise to the level of a covered loss. For instance, in Newman Myers Kreines Gross Harris, P.C. v. Great N. Ins. Co.,xvi the insured lost access to its office during Hurricane Sandy because the power company preemptively shut off power in anticipation of the storm. The court held that mere loss of access did not constitute “direct physical loss or damage” under the policy. The court distinguished precedent holding that the presence of noxious gases or fumes can be direct physical loss or damage, because while those cases “did not involve tangible, structural damage to the architecture of the premises”, “the critical policy term at issue, requiring ‘physical loss or damage,’ does not require that the physical loss or damage be tangible, structural or even visible.” xvii The court held that because there was no physical damage to the property, the loss was not covered by the policy.xviii
Business Interruption Coverage
Many commercial property policies include business interruption coverage that typically covers lost revenue, rent or lease payments, relocation or temporary location costs, employee wages, taxes, and/or loan payments resulting from a “covered cause of loss.” “Traditional business interruption coverage is triggered when four elements are met: (1) a direct physical loss of or damage to property (2) caused by a covered peril (3) that results in a suspension of business operations (4) that causes a loss of business income.” xix Typical examples of covered events include fire, severe weather events, and natural disasters.
As discussed above, the first hurdle to coverage will likely be whether COVID-19 has caused “direct physical loss of or damage to property.” Specific policy endorsements and exclusions will no doubt receive a lot of attention by policyholders, insurers and courts alike in determining to what extent business losses stemming from COVID-19 may be covered. These provisions are discussed below. Whether a claim will be covered depends on the terms and conditions of the policy in question. However, in a white paper report published in late January, Crawford & Co. (a large independent claims manager) stated that “successful claims under business interruption coverage for infection are not common." xx
Civil Authority and Prevention of Ingress/Egress Endorsements
The implementation of “stay at home” orders have forced many businesses to close or have otherwise resulted in lost productivity, revenue, and customers. Courts will be forced to grapple with whether losses caused by these government orders fall under the civil authority or ingress/egress endorsements.
Civil authority endorsements typically apply when a government authority “prohibits access” to the business because of a “direct physical loss of or damage to property.” Thus, coverage likely will still turn on whether there was a direct physical loss or damage. It is also likely that courts will look at whether access to the business was prohibited. Issues to coverage will likely include whether a government order applied to the business at all. There are a multitude of exemptions for “essential” businesses and there are also many businesses limiting operations because of government recommendations as opposed to orders.
Ingress/egress endorsements may be broader and, thus, more likely to apply. “Ingress or egress” provisions typically apply when access to a covered location is prohibited by a “covered cause of loss.” The policy provision may or may not require physical damage to your property. If it does not, arguments for coverage may be stronger.
Several cases have interpreted civil authority and ingress/egress provisions where there is not clear evidence of tangible property damage that may prove instructive to how courts will interpret these provisions in light of COVID-19. Some have concluded that actual physical damage is not required while others have not.
The Eastern District of North Carolina in Fountain Powerboat Indus., Inc. v. Reliance Ins. Co. held that the civil authority and ingress/egress provisions did not require physical loss to the property for business interruption coverage to apply.xxi Fountain Powerboat Industries (“Fountain”) manufactured boats and boating equipment and lost access to its manufacturing facility as a result of flooding caused by Hurricane Floyd. In finding coverage, the court held that property damage or a physical loss was not required under either the ingress/egress or “civil authority” provisions in the policy, but covered any loss sustained due to lack of access to the property.xxii In so holding, the court relied on the policy’s language, noting that “[a] ‘loss’ is not predicated on physical damage but is one category of recovery along with damage and destruction as indicated by the use of the alternative coordinating conjunction ‘or’." xxiii
The Southern District of Texas, in Houston Cas. Co. v. Lexington Ins. Co., found coverage under a civil authority extension when the insured, Universal Studios, was forced to close its amusement park for a day due to a declaration of a state of emergency by Florida Governor Jeb Bush due to Hurricane Floyd threatening the Florida Coast.xxiv Hurricane Floyd subsequently changed course and did not make landfall in Florida, so Universal Studios did not suffer any physical damage to its property.xxv Universal submitted a business interruption claim to its insurer, which was paid.xxvi However, a reinsurer denied payment to the insurer arguing Universal Studios was not entitled to coverage as the property had not suffered any physical damage.xxvii Based largely on the FountainBoat decision and the terms and conditions of the policy, the court found that the original insurer had properly paid Universal Studio’s claim for coverage under the “civil authority” and “ingress/egress” provisions of the policy despite the absence of damage to the covered property.xxviii
In Sloan v. Phoenix of Hartford Ins. Co., a Michigan court addressed the issue of whether losses claimed by the insured theater, incurred because of a curfew imposed in the wake of rioting in Detroit, were covered in the absence of physical damage to the theater.xxix One section of the policy provided coverage for losses incurred “during the period of time, not exceeding two consecutive weeks, when as a direct result of the peril(s) insured against, access to the premises described is prohibited by order of civil authority.”xxx The court observed that this last provision failed to specifically require physical damage to the premises as a prerequisite for coverage, so coverage was provided and benefits were payable when, as a result of one of the perils insured against, access to the insured premises was prohibited by order of civil authority.xxxi
On the contrary, in United Air Lines, Inc. v. Insurance Co. of the State of Penn., the Second Circuit held that United, whose facilities did not suffer direct physical damage as a result of the September 11 attack on the Pentagon, could not recover for its lost earnings caused by the disruption of flight service and the government’s temporary shutdown of the Washington D.C. airport.xxxii The insurance policy’s civil authority provision required the civil authority to be a “direct result of damage to adjacent premises.” xxxiii The court denied coverage on the ground that United’s business interruption at the airport was caused by the threat of additional terrorist attacks, not by damage at the near-by Pentagon.xxxiv
Civil authority coverage may also require that the order be related to the “covered event” leading to the direct physical loss.xxxv In 2011, the Fifth Circuit provided the following framework for reviewing such claims in Dickie Brennan & Co., Inc. v. Lexington Ins. Co.:
[T]o prove coverage under the civil authority provision, the insured must establish a loss of business income: (1) caused by an action of civil authority; (2) the action of civil authority must prohibit access to the described premises of the insured; (3) the action of civil authority prohibiting access to the described premises must be caused by direct physical loss of or damage to property other than at the described premises; and (4) the loss or damage to property other than the described premises must be caused by or result from a covered cause of loss as set forth in the policy.xxxvi
There, the New Orleans mayor issued an evacuation order in anticipation of a hurricane. The evacuation order said nothing about property damage, so the court found that the insured “failed to demonstrate a nexus between any prior property damage and the evacuation order.” xxxvii
As related to COVID-19, most business shut downs are tied to preventing the spread of the disease from person to person, not to prevent property damage or even decontaminate property because the virus is known or suspected to be present. Depending on the specific language of the policy, this lack of nexus between the order and the covered physical loss—to the extent contamination with COVID-19 is considered a direct physical loss—may prevent civil authority coverage from applying.
Communicable Disease Endorsement
Some commercial property policies contain a communicable disease endorsement, also known as “notifiable disease” endorsement. These endorsements vary by policy. For example, Axa (a European insurance provider) recently stated, when our business interruption policies provide an endorsement for coverage “for infectious diseases, they list the diseases by name. Only for those diseases will they compensate for financial losses resulting from premises having to close. Our wordings don’t refer to a general class of notifiable diseases, but they name each disease individually. When COVID-19 was added to the list of notifiable diseases in England, it did not change policy coverage.” xxxviii Some policies identify a fixed list of diseases, while others generally include all diseases that are classified as notifiable.xxxix
In Catholic Med. Ctr. v. Fireman's Fund Ins. Co.,xl a hospital was required to destroy certain surgical instruments because they were potentially contaminated with a fatal communicable disease. The hospital filed a claim with its commercial property insurer seeking reimbursement for the destroyed instruments. The policy extended coverage for communicable disease where the insured suffered a “direct physical loss or damage” to property caused by a “covered communicable disease event …” The endorsement defined “communicable disease” as “any disease caused by a biological agent that may be transmitted directly or indirectly from one human or animal to another” and defined “communicable disease event” as an “event in which a public health authority has ordered that the premises described in the Declarations be evacuated, decontaminated, or disinfected due to the outbreak of a communicable disease at such premises.” The court held that there was no “communicable disease event” to trigger the policy, because there was no decontamination or disinfection of the premises. The court suggested that had the premises been decontaminated or disinfected, the damage to the surgical instruments would have been covered. However, because it was not, the “gateway to coverage” was not met.
In instances where parties have suffered a loss due to COVID-19, but have not decontaminated or disinfected their premises, this case suggests their loss is not covered. However, if the gateway to coverage is met, i.e. premises are disinfected or decontaminated, certain costs associated with damage to the insured property may be covered, such as costs associated with: (1) testing, monitoring, treating, detoxifying, disinfecting, and neutralizing the insured property; (2) cleaning, removing, or disposing debris from the insured property; and (3) replacement of consumable goods at the insured property.
Crisis Management Endorsement
Another source of potential coverage may come under a crisis management endorsement. For instance, in Catholic Med. Ctr. v. Fireman's Fund Ins. Co.,xli the hospital included an endorsement for a “covered crisis event,” which was defined as:
Necessary closure of your covered premises due to any sudden, accidental and unintentional contamination or impairment of the covered premises or other property on the covered premises which results in clear, identifiable, internal or external visible symptoms of bodily injury, illness, or death of any person(s). This includes covered premises contaminated, by communicable disease, Legionnaires' disease, but does not include premises contaminated by other pollutants or fungi.xlii
There, the court held this coverage was inapplicable because the hospital was not required to close the premises because of the contamination.xliii This type of coverage may be triggered in instances where businesses are required to close because of a known COVID-19 case on the premises.
Exclusion for Pollutant or Contaminant
Even if losses caused by the COVID-19 pandemic are covered under a policy’s insuring language or endorsement, exclusions in the policy may apply to bar coverage. One exclusion insurers are likely to focus on is the pollutant or contaminant exclusion. The question here will likely turn on whether a virus is a pollutant or contaminant. Several courts have considered this question related to other viruses or bacteria. Some have held viruses not be pollutants, while other courts have held that viruses fall within the scope of a pollution exclusion. Compare Westport Insurance Corp. v. VN Hotel Group, LLC , 761 F. Supp. 2d 1337, 1343-44 (M.D. Fla. 2010) (holding that the pollution exclusion did not apply because Legionella bacteria are living organisms and therefore not pollutants) with First Specialty Ins. Corp. v. GRS Mgmt. Associates, Inc., 08-81356-CIV, 2009 WL 2524613, at *5 (S.D. Fla. Aug. 17, 2009) (“Clearly, the record evidence demonstrates that the substance in the swimming pool was a viral contaminant and a harmful microbe. Thus, the pollutant exclusion applies here.”); Nova Cas. Co. v. Waserstein, 424 F. Supp. 2d 1325, 1332 (S.D. Fla. 2006) (“‘living organisms,’ ‘microbial populations,’ ‘microbial contaminants,’ and ‘indoor allergens’ fit the ordinary definition of a ‘contaminant,’ and, as alleged in the underlying state court complaints, had a ‘contaminating’ effect.).
Exclusion of Loss Due to Bacteria or Virus
Some policies expressly exclude losses associated with bacteria or virus. A typical exclusion will exclude coverage for “loss or damage caused by or resulting from any virus, bacterium or other microorganism that induces or is capable of inducing physical distress, illness or disease.” Policies containing this exclusion are unlikely to provide coverage for COVID-19 related losses. However, courts may find that the presence of this exclusion in some policies supports the argument that policies without this exclusion apply to virus related losses.
As the facts related to business closures and other losses stemming from COVID-19 are better understood and courts begin to address business interruption coverage under specific policy provisions, we will get more clarity as to what claims may and may not be covered. Because insurance policies are a matter of contract, the specific policy language and fact patterns will be determinative of whether or not a particular claim is covered.
I. Commercial General Liability Insurance
In addition to first-party claims discussed above, commercial general liability, or CGL, policies may be a source of coverage for third-party claims related to COVID-19. CGL policies protect businesses against liability arising out of bodily injury or property damage. The policies generally apply to bodily injury or property damage caused by a covered “occurrence,” which is typically defined as an accident. Businesses may also be faced with property damage claims from third parties related to COVID-19. Because the facts and circumstances surrounding COVID-19 are unfolding in real time, it is impossible to predict what future bodily injury or property damage claims may be brought that may implicate CGL policies. However, we can anticipate that coverage may initially turn on whether the occurrence was an “accident. Factors such as the insured’s knowledge of persons on the premises with COVID-19 and precautions taken or not taken to prevent the spread of COVID-19 will likely be factors a court will consider. Even if an insured can show that the bodily injury or property damage was caused by an accident, policy exclusions may still bar coverage. Each policy is different, but exclusions to look out for include pollution exclusions, fungi or bacteria exclusions and communicable disease exclusions.
The losses associated with COVID-19 are varied and far-reaching. Coverage will ultimately depend upon individual policy language, how each state interprets such policy provisions, and the facts giving rise to the claim for coverage. The first lawsuits have begun to pop up around the country, and in the coming months and years, judges will begin to provide some guidance on the extent to which insurance may provide coverage for losses associated with COVID-19. Because of the far reaching impact of this pandemic, legislatures are also beginning to weigh in on this issue. As of the writing of this article, New Jersey, Ohio, Massachusetts and New York are considering legislation that would mandate some business interruption coverage for certain policyholders and provide insurers with reimbursement for paid claims. Because of the enormous risk of loss to businesses and the insurance industry arising from this unprecedented global shut down of businesses, legislative measures to spread this risk may be the best outcome for all.
i https://www.cdc.gov/coronavirus/2019-ncov/prepare/transmission.html (last visited March 26, 2020).
ii 131 Fed. Appx. 823, 824 (3d Cir. 2005).
iii Id. at 825.
iv Id. at 826-827.
v Id. at 826.
vi Id. citing In Port Authority of New York & New Jersey v. Affiliated FM Ins. Co., 311 F.3d 226, 236 (3d Cir.2002).
vii 284 Va. 547, 552, 736 S.E.2d 321, 325 (2012).
viii Id. at 710.
ix Id. at 710-712.
x Id. at 712-713.
xi Id. at 713-715.
xii Id. at 715-718.
xiii 2:12-CV-04418 WHW, 2014 WL 6675934, at *6 (D.N.J. Nov. 25, 2014).
xv Id. at *7.
xvi 17 F. Supp. 3d 323, 330 (S.D.N.Y. 2014).
xvii Id. at 329-330.
xviii Id. at 331.
xix Matt Weaver et. al., September 11, 2001, and the Impact of Actions by Civil Authorities Lessons Learned, Brief, Fall 2016, at 21.
xx The report can be found at https://www.crawco.co.uk/resources/the-insurance-impacts-of-the-2019-novel-coronavirus.
xxi 119 F. Supp. 2d 552 (E.D.N.C. 2000).
xxii Id. at 557.
xxiv Hous. Cas. Co. v. Lexington Ins. Co., No. H-05-1804, 2006 U.S. Dist. LEXIS 45027, at *1 (S.D. Tex. June 15, 2006).
xxv Id. at *1-*3.
xxviii Id. at *1-*3, *8.
xxix 46 Mich. App. 46, 51, 207 N.W.2d 434, 436-37 (1973)
xxx Id. at 436.
xxxi Id. at 436-37.
xxxii 439 F.3d 128, 129 (2d Cir. 2006)
xxxiv Id. at 134–35.
xxxv See e.g. Dickie Brennan & Co., Inc. v. Lexington Ins. Co., 636 F.3d 683, 685 (5th Cir. 2011) (holding that where the evacuation order did not reference property damage, the insured “failed to demonstrate a nexus between any prior property damage and the evacuation order”); Kelaher, Connell & Conner, P.C. v. Auto-Owners Ins. Co., 4:19-CV-00693-SAL, 2020 WL 886120, at *1 (D.S.C. Feb. 24, 2020) (holding that an evacuation order issued because of an oncoming storm was not issued “because of” damage or destruction of property); Bamundo, Zwal & Schermerhorn, LLP v. Sentinel Ins. Co., Ltd., 13-CV-6672 RJS, 2015 WL 1408873, at *5 (S.D.N.Y. Mar. 26, 2015) (holding that because the civil authority order was issued because of flooding, coverage under the endorsement was precluded under the flood exclusion); United Air Lines, Inc. v. Ins. Co. of State of PA, 439 F.3d 128, 131 (2d Cir. 2006) (no coverage for insured when airport closed following 9/11 terrorist attacks because closure was not due to property damage); but see Sloan v. Phoenix of Hartford Ins. Co., 46 Mich. App. 46 (“[I]rrespective of any physical damage to the insured property, coverage was provided and benefits were payable when, as a result of one of the perils insured against, access to the insured premises was prohibited by order of civil authority, and we so hold.”); Houston Cas. Co. v. Lexington Ins. Co., No. CIV.A. H-05-1804, 2006 WL 734810, at *6 (S.D. Tex. June 15, 2006) (finding coverage where amusement park was closed due to a mandatory evacuation without requirement for property damage); Assurance Co. of Am. v. BBB Serv. Co., 265 Ga. App. 35 (finding coverage where other property, not the insured premises, was damaged leading to the evacuation order).
xxxvi Dickie Brennan & Co., Inc. v. Lexington Ins. Co., 636 F.3d 683, 685 (5th Cir. 2011) (emphasis added).
xxxvii Id. at 686.
xxxviii See https://www.insuranceage.co.uk/insurer/7500931/axa-confirms-coronavirus-business-interruption-coverage?utm_medium=email&utm_campaign=IA.Daily_RL.EU.A.U&utm_source=IA.DCM.Editors_Updates
xl 14-CV-180-JL, 2015 WL 3463417, at *4 (D.N.H. June 1, 2015).
xli 14-CV-180-JL, 2015 WL 3463417, at *4 (D.N.H. June 1, 2015).
xlii Id. at *2.
xliii Id. at *5.
Partner Courtney Ervin, when asked to describe herself as a lawyer, says, “I’m a problem-solver.” While she takes pride in securing victories for her clients in the courthouse, she also finds immense satisfaction using her business acumen to defuse disputes early, when possible. Courtney’s practice focuses on high-stakes commercial litigation in state and federal court and in arbitration. She represents clients in a wide-range of industries, including insurance, construction, energy, oil and gas, real estate, private equity, information technology, and health care.
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Joshua Bauer represents businesses and individuals in a variety of commercial litigation matters. He works with clients to craft creative solutions to their business problems and has broad experience advising companies in a variety of industries, including real estate, insurance, healthcare, and financial institutions. This prior representation includes claims for breach of contract, general negligence, trademark infringement, conversion, theft of trade secrets, franchise disputes, regulatory compliance, and breach of fiduciary duty. Josh also represents clients in insurance coverage matters.
Amanda Goldstein represents businesses and individuals in commercial litigation matters. Her experience includes business litigation, including claims for breach of contract, fraud, violations of the Texas Deceptive Trade Practices Act, fraudulent transfer, and trade dress infringement. Amanda also represents clients in insurance coverage matters.