Sixth Circuit Holds Salmonella Outbreak Constitutes a Single Occurrence Under CGL Policies Despite Lot Endorsement

The U.S. Court of Appeals for the Sixth Circuit, applying Ohio law, affirmed summary judgment in favor of an insured food manufacturer and held that thousands of bodily injury claims arising from an alleged salmonella contamination event constituted a single “occurrence” under commercial general liability policies for purposes of determining the number of applicable retained limits.... By: Wiley Rein LLP