Adjusting Today Basis for Institutes CE Courses The Institutes, the leader in providing knowledge solutions for risk management and the property/casualty insurance industry, offers continuing education courses based on technical information compiled from issues of Adjusting Today. The courses — “Valuing a Property Insurance Claim” and “Natural Disasters: Coverage Issues”— include seven modules each and are approved for credit by insurance departments in most states. They are offered to property insurance producers, adjusters or both, depending on the state, for up to three continuing education credit hours per course. More information is available at CEU.com. CORPORATE OFFICE 126 Business Park Drive Utica, New York 13502 800.382.2468 Outside U.S. (315) 797.3035 FAX: (315) 272.2054 Editor@AdjustingToday.com Copyright © 2019 Rising Phoenix Holdings Corporation. All Rights Reserved. Adjusters International and the AI logo are registered trademarks of Rising Phoenix Holdings Corporation. Follow Adjusting Today on Facebook & Twitter: Facebook.com/AdjustersInternational Twitter.com/AdjustingToday ADJUSTING TODAY is published as a public service by Adjusters International, Inc. It is provided for general information and is not intended to replace professional insurance, legal or financial advice for specific cases. ADJUSTINGTODAY® Adjust ingToday. com View our entire catalog of back issues, download PDF versions, subscribe and contact the editor. WEB ADDRESSES AdjustersInternational.com AdjustingToday.com PUBLISHER Ronald A. Cuccaro, SPPA EDITOR Sheila E. Salvatore AT19 3050 Mr. Harrington is an independent insurance writer and communications specialist. He served for over 20 years as communications director for the American Association of Insurance Services (AAIS). His work has been published in Best’s Review, Rough Notes, publications of The Institutes, and elsewhere. Joseph S. Harrington, CPCU, ARP ABOUT THE AUTHOR ____________________ 1 Timoney Knox, LLP, “Survey of State Law Regarding Enforceability of Anti-Concurrent Causation Clauses,” accessed on April 23, 2018 at http://www.timoneyknox.com/insuranceindustry/survey-of-state-law-regarding-enforceability-of-anti-concurrent-causation-clauses. 2 Safeco Insurance Co. v. Guyton, 692 F.2d 551 (1982, U.S. Court of Appeals, Ninth Circuit). 3 Premier Insurance Co. v. Welch, 140 Cal. App. 3d 720 (1983). 4 Garvey v. State Farm Fire & Casualty Co., 770 P.2d 704 (1989, California Supreme Court). 5 State Farm Fire and Casualty Co. v. Von Der Lieth, 218 Cal. App. 3d 964 (1990). 6 Jonathan Bukowski, “The Realty (sic) of Colorado’s Anti-Concurrent Cause Exclusion Law,” Merlin Law Group, Oct. 14, 2017, accessed at https://www.propertyinsurancecoveragelaw. com/2017/10/articles/insurance/the-realty-of-colorados-anti-concurrent-cause-exclusion-law/. 7 Erin Dunnavant. “Court Rejects Jury Instruction Inconsistent with Concurrent Causation Doctrine; Remands for New Trial,” Merlin Law Group, Feb. 8, 2018, accessed at https:// www.propertyinsurancecoveragelaw.com/2018/02/articles/court-opinion/court-rejects-juryinstruction-inconsistent-with-concurrent-causation-doctrine-remands-for-new-trial/. Adjusters and policyholders may benefit from how this court defined how the burden of proof shifts from policyholder to insurer in concurrent causation cases.
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