October 15, 2025 | JacobiJournal.com — The Eleventh Circuit Court of Appeals has reaffirmed that insurers cannot easily escape their duty to defend when a malpractice complaint raises allegations potentially covered by professional liability insurance. The court’s decision underscores how narrowly exclusions must be applied when determining an insurer’s defense obligations toward attorneys and law firms.
Court Rejects Overbroad Use of Policy Exclusions
In the dispute, an insurer sought to avoid defending an attorney accused of mishandling a client matter, citing conflict-of-interest and misappropriation exclusions. The appellate panel disagreed, holding that such exclusions did not clearly eliminate coverage for the allegations presented.
The judges emphasized that the duty to defend is broader than the duty to indemnify, meaning insurers must step in as long as any claim in the complaint may fall within coverage. This decision aligns with the Eleventh Circuit’s consistent stance favoring insureds in ambiguous defense scenarios.
Implications for Professional Liability Coverage
Legal analysts note that the ruling strengthens the protection afforded to lawyers under professional liability policies, particularly in jurisdictions governed by Eleventh Circuit precedent. The case signals to insurers that attempts to rely on vaguely worded exclusions may fail where the underlying facts could still support coverage.
“This opinion is another reminder that insurers carry a heavy burden when attempting to disclaim their defense obligations,” one coverage attorney explained. “Courts are increasingly unwilling to let carriers off the hook based on speculative exclusions.”
Broader Context for Insurers and Law Firms
The Eleventh Circuit’s decision follows a growing national trend requiring insurers to honor defense commitments when policy wording is unclear. For law firms, the ruling highlights the importance of reviewing policy terms, especially exclusions tied to conflicts or client fund handling.
Industry observers predict that this case will be cited in upcoming disputes involving the scope of an insurer’s duty to defend under professional liability and errors-and-omissions policies.
For a full summary of recent federal coverage cases, visit the Insurance Law Center at Cornell Law School.
FAQs: Eleventh Circuit Insurer Duty to Defend Ruling 2025
What did the Eleventh Circuit decide about insurer obligations?
The court ruled that the insurer must defend the attorney and firm in a malpractice lawsuit because the claims could fall within the scope of the policy.
Why did the insurer try to deny coverage?
It cited exclusions related to conflict of interest and misappropriation, but the court found these did not clearly apply to all alleged conduct.
How does this affect other law firms with similar policies?
It sets a strong precedent favoring insureds by confirming that any doubt in coverage should be resolved in favor of providing a defense.
Where can readers learn more about insurer defense duties?
Readers can explore coverage principles at Cornell Law’s Insurance Law Center.
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