SANTA ANA, Calif.—Only a named insured, not an additional insured, can satisfy a general liability policy’s self-insured retention to trigger coverage, a California appellate court has ruled in a construction defect case.
The dispute in Forecast Homes Inc. et al. vs. Steadfast Insurance Co. stemmed from a developer’s requirement that subcontractors agree to defend and hold it harmless for any liability arising from the subcontractors’ work. Forecast, the developer, also required subcontractors to name it as an additional insured on their general liability policies purchased from Steadfast.