WI STATEWisconsin Supreme Court
2004

American Family Mutual Insurance v. American Girl, Inc.

2004 WI 2Wisconsin Supreme Court • Decided 2004Enforced

HOLDING

A soil engineering subcontractor's faulty site-preparation work caused a building to settle and become unsafe, requiring demolition. The general contractor's insurance carriers denied coverage, claiming contractual liability and business risk exclusions applied. Wisconsin's Supreme Court ruled that the CGL policies must cover the property damage because it resulted from an accidental occurrence, even though the damage was also actionable as a contract breach. This means subcontractors and contractors cannot be left without insurance protection simply because their work failures are both negligent and contractually guaranteed.

KEY FINDINGS

Broad Indemnification

CGL insurance covers property damage from faulty subcontractor work even when the damage is also a breach of contract—accidental occurrence coverage applies regardless

Flow-Down

Contractual liability exclusions do not eliminate coverage for property damage that stems from an unintended accident, only intentional or expected losses

Dispute Resolution

Subcontractors should ensure their contracts flow down insurance requirements to protect the general contractor, as GCs will look to their own policies first and may pursue indemnification claims

FULL COURT OPINION