Harriman v. Associated Industries Insurance Company, Inc., No. 22-1542 (4th Cir. 2024)
Annotate this CaseThe case involves Susan Harriman and Associated Industries Insurance Company. Harriman was an investment advisor who was sued for defamation by Palmaz Scientific after she shared damaging information about the company with her clients. Harriman sought coverage from Associated, with which her employer had an insurance policy, for her defense against the defamation allegations. Associated, however, denied coverage, arguing that the policy only covered wrongful acts committed in the rendering or failure to render professional services on behalf of the company. The United States Court of Appeals for the Fourth Circuit affirmed the lower court's summary judgment in favor of Associated. The court held that Associated was never obligated to defend Harriman because the claims triggered both its policy and a separate policy Harriman had with Travelers Insurance Company, making Travelers the primary coverage provider. The court also held that Harriman failed to present evidence that would allow a factfinder to conclude that Associated lacked a reasonable basis for its coverage decision, thereby dismissing her bad faith claim.
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