102 Ohio App. 3d 679 - Helberg v. National Union Fire Insurance’s Empirical Analysis
1995
Citation profile
6 federal appellate · 2 district · 12 state decisions
How this case has been cited
Cited by 33 later decisions — most recently March 2022 · most notably Cast Steel Products, Inc. v. Admiral Insurance (2003), Checkrite Ltd., Inc. v. Illinois Nat. Ins. Co. (2000)
6 federal appellate · 2 district · 12 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on King v. Nationwide Insurance · Faruque v. Provident Life & Accident Insurance · United States v. Strip
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“for 'any claim * * * first made against the insured and reported to [the Insurer] during the policy period.' " Helberg at 680-81 . Under that language, coverage was not available to the insured since the claim was not reported until several weeks after the policy period had ended. However, another provision in the policy stated that coverage was available "to any claim arising out of any acts or omissions occurring prior to the effective date of the first policy issued to the named insured by [the Insurer] and continuously renewed thereafter if any insured on such date knew or could have reasonably foreseen that such acts or omissions might be expected to be the basis of a claim or suit.”
1 later decision quote this exact passage · from the majority“This language indicates that the parties expected coverage to be continuous if the policy was renewed at each successive policy expiration. Taken in conjunction with [the section requiring reporting during the policy period or during an extended reporting period], this element of the contract contributes to the ambiguity of when a claim must be reported. Thus, the contract should be construed in favor of ... the insured.”
1 later decision quote this exact passage · from the majority“of the policy as one of those circumstances demanding the purchase of an extended reporting endorsement excludes a”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.