FEDERALCourt of Appeals for the Fifth Circuit
2013

Duval v. Northern Assurance Co. of America

722 F.3d 300Court of Appeals for the Fifth Circuit • Decided 2013Enforced

HOLDING

A worker injured on an offshore platform sued a vessel operator (Deep Marine). Deep Marine tried to get its insurance company to defend and indemnify it under a master services agreement with the project owner (BHP). The Fifth Circuit ruled that indemnification and insurance obligations in a contract only bind the two parties who signed it—insurers cannot be forced to enforce those obligations just because they're mentioned in the contract. This protects insurers from unexpected liability but means contractors must carefully manage their own defense and indemnity obligations.

KEY FINDINGS

Broad Indemnification

Indemnity clauses in your contracts only create obligations between you and the other party—they don't automatically bind your insurance company or create rights for third parties

Insurance Requirements

If you agree to indemnify a client, you must ensure your insurance policy actually covers that obligation; don't assume it does just because the contract requires it

Flow-Down

When tendering a claim to your insurer, the insurer can still refuse coverage if the contract obligation falls outside what the policy actually covers

FULL COURT OPINION