Physicians Insurance Co. v. Williams

This appeal involved the interpretation of a claims-made professional liability insurance policy that Appellant Physicians Insurance Company of Wisconsin, Inc., d.b.a. PIC Wisconsin (PIC), issued to nonparty dentist Hamid Ahmadi, D.D.S. The policy covered dental malpractice claims made against Dr. Ahmadi and reported to PIC during the policy period. On cross-motions for summary judgment, the district court determined that PIC received constructive notice of Respondent Glenn Williams’s malpractice claim against Dr. Ahmadi while the policy was in force and held that this was enough to trigger coverage. Upon review, the Supreme Court reversed, finding that a "report" of a potential demand for damages to qualify as a "claim" required sufficient specificity to alert the insurer’s claim department to the existence of a potential demand for damages arising out of an identifiable incident, involving an identified or identifiable claimant or claimants, with actual or anticipated injuries. The Court did not find an ambiguity that would permit the PIC policy to have been triggered by the report of a default judgment against the doctor filed in public records. As such, the Court remanded the case with instructions to enter summary judgment in favor of PIC.