Liberty Univ. v. Citizens Ins. Co., No. 14-2254 (4th Cir. 2015)
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Citizens Insurance appealed the district court's ruling that it had a duty to defend Liberty University in an underlying action. In the underlying action, Janet Jenkins filed suit against Liberty University, alleging that the school participated in a scheme to kidnap Jenkin's daughter in order to disrupt the parent-child relationship. The court concluded that the district court erroneously interpreted the Jenkins Complaint, the Separation of Insureds
provision, and Virginia law. In this case, the Jenkins Complaint does not allege an "occurrence," and it triggers the policy's coverage exclusions. Accordingly, Citizens Insurance has no duty to defendant Liberty University. The court vacated and remanded.
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