{"id":5400,"date":"2025-08-01T13:19:53","date_gmt":"2025-08-01T13:19:53","guid":{"rendered":"https:\/\/www.fwhtlaw.com\/blog\/?p=5400"},"modified":"2025-08-04T12:18:26","modified_gmt":"2025-08-04T12:18:26","slug":"whats-in-a-name-your-coverage-extensions-thats-what","status":"publish","type":"post","link":"https:\/\/www.fwhtlaw.com\/blog\/2025\/08\/01\/whats-in-a-name-your-coverage-extensions-thats-what\/","title":{"rendered":"What\u2019s In A Name? \u201cYour\u201d Coverage Extensions, That\u2019s What."},"content":{"rendered":"
By Matthew G. Nelson<\/h6>\n
\u00a0Matt is a member of the firm\u2019s Construction Law Department. He can be reached at 612.359.7611 or mnelson@fwhtlaw.com<\/a><\/span><\/h6>\n

Introduction<\/em><\/strong><\/p>\n

\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 So, what really<\/em> is in a name? The tragic protagonist Juliet was not the first to consider this question, nor the last. In June, the United States Court of Appeals for the Eighth Circuit determined that, when it comes to insurance coverage, a whole lot depends on precisely how and where names, and their related pronouns and possessive adjectives, appear in an insurance policy. Essentially<\/em>, an \u201cAdditional Named Insured\u201d is not the same as an \u201cadditional<\/em> \u2018Named Insured.\u2019\u201d Subject to other policy provisions, the coverage afforded to the former may be narrower than that afforded to the latter.<\/p>\n

\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The upshot? Following a collapse on a project site, a developer (and its construction lender) did not have access to millions of dollars in builder\u2019s risk coverage for soft costs and loss of rental income, incurred in connection with delayed project completion caused by the collapse.<\/p>\n

\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The reader is invited to decide which might be worse: Pondering with Juliet\u2014from a breezy balcony\u2014a name\u2019s ability to constrain one\u2019s social options; or, being embroiled in insurance coverage claims and litigation for nearly ten years, only to receive a decision of no coverage, because the various insureds were not properly named in the insurance policy.<\/p>\n

\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 At the risk of sounding unpoetic, I\u2019d say the latter.<\/p>\n

\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Read further to learn how this unfortunate result materialized, and steps you can take to avoid a similar fate.<\/p>\n

BCC Partners<\/em><\/strong><\/p>\n

    \n
  1. \n
      \n
    1. \n
        \n
      1. \u00a0 \u00a0 Background<\/strong><\/li>\n<\/ol>\n<\/li>\n<\/ol>\n<\/li>\n<\/ol>\n

        \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The controversy in BCC Partners, LLC v. Travelers Prop. Cas. Co. of Am.<\/em>[1]<\/a> developed from fairly ordinary circumstances. The owner BCC obtained construction financing from a lender and hired the contractor Blanton to build its apartment project in Creve Coeur, Missouri. BCC\u2019s construction loan required that it be included as an insured on a builder\u2019s risk policy covering its interest in the project and that included \u201ccoverage for delay in rents associated with a delay to completion of the Project.\u201d<\/p>\n

        \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 In turn, BCC\u2019s general contract with Blanton obligated Blanton to obtain certain types and limits of insurance, including builder\u2019s risk coverage for the project, and to include BCC as an additional insured on the policy. Blanton obtained a builder\u2019s risk policy from Travelers, insuring against loss to \u201cCovered Property\u201d at the project, which included \u201cPermanent Works\u201d (such as materials or equipment incorporated or to be incorporated into the apartment building) and \u201cTemporary Works\u201d (scaffolding or formwork, for instance). The policy also included a \u201cConstruction Pak \u2013 Builders\u2019 Risk Special Time Element Coverage Form,\u201d affording coverage for soft costs (such as \u201cgeneral overhead and \u201cinterest on money borrowed to finance construction\u201d) as well as loss of business income or lost rental value following the occurrence of an insured peril. While Blanton obtained the builder\u2019s risk policy, the cost was passed on to BCC as a component of the general contract price.<\/p>\n

        \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 A retaining wall collapsed during the project, leading to damage to covered property and delays to project completion. Blanton sued Travelers and obtained a verdict of $330,000 for the direct cost to remove and replace the collapsed retaining wall. BCC commenced arbitration against Blanton and several of its subcontractors for delays to the project, and obtained an award exceeding $7,200,000. Blanton then filed for bankruptcy.<\/p>\n

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        1. \n
            \n
          1. \n
              \n
            1. \u00a0 \u00a0 The Claim<\/strong><\/li>\n<\/ol>\n<\/li>\n<\/ol>\n<\/li>\n<\/ol>\n

              \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 While these disputes were in active litigation or arbitration, BCC advised Travelers that both BCC and its lender were \u201cAdditional Named Insureds\u201d under the following policy provision:<\/p>\n

              The following persons or organization are included as Additional Named Insureds when you have agreed in a written contract or written agreement, executed prior to loss, to name such persons or organizations as an Additional Named Insured<\/u><\/strong>, but only to the extent of their financial interest in the Covered Property: *** Owners<\/u><\/strong> of Covered Property; *** Mortgagees<\/u><\/strong> or loss payees[.]<\/p>\n

              A Travelers adjuster responded:<\/p>\n

              [W]e are aware of the additional interest of BCC Partners LLC and Commerce Bank and will protect their financial interest in the claim as named insureds<\/u><\/strong> per the builders risk policy.<\/p>\n

              \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The following day, BCC submitted a claim to Travelers under the policy\u2019s coverage extension for \u201cRental Value\u201d and \u201cSoft Costs\u201d included in the \u201cConstruction Pak \u2013 Builders\u2019 Risk Special Time Element Coverage Form,\u201d which provided, in relevant part:<\/p>\n

              Throughout this Coverage Form, the words \u201cyou<\/u><\/strong>\u201d and \u201cyour<\/u><\/strong>\u201d refer to the Named Insured shown in the Declarations<\/u><\/strong> *** We will pay the actual loss of \u201crental value\u201d you<\/u><\/strong> sustain due to *** Delay in start up of your<\/u><\/strong> business activities *** We will pay your<\/u><\/strong> \u201csoft costs\u201d during the \u201cperiod of delay in completion\u201d.<\/p>\n

              \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Travelers initially advanced $200,000 to BCC toward its rental losses and soft costs. At Travelers\u2019 request, during 2017 and 2018 BCC provided further backup documentation quantifying its mounting rental losses or soft cost outlays. However, in 2019 Travelers denied coverage and reserved the right to recover its advance made under the claim.<\/p>\n

                \n
              1. \n
                  \n
                1. \n
                    \n
                  1. \u00a0 \u00a0 Lawsuit and Appeal<\/strong><\/li>\n<\/ol>\n<\/li>\n<\/ol>\n<\/li>\n<\/ol>\n

                    \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 BCC eventually issued a demand to Travelers for the policy limits remaining under the Special Time Element Coverage Form. Travelers demurred and reiterated its right to recover the $200,000 it advanced to BCC. BCC then sued Travelers in federal district court and both parties brought cross-motions for summary judgment. The court denied BCC\u2019s motion and granted Travelers\u2019 motion.<\/p>\n

                    \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 BCC argued that the coverage extension must be interpreted broadly to apply to all insureds. The district court rejected this argument as contrary to the plain terms of the coverage extension. Blanton was the only Named Insured shown in the policy declarations. As such, the pronoun \u201cyou\u201d and possessive adjective \u201cyour\u201d in the Special Time Element Coverage Form could only refer to Blanton, even if, practically speaking, Blanton as the contractor would not (directly) incur lost rents or soft costs. According to the court, this did not render the coverage provided by the Special Time Element Coverage Form illusory, but only meant that the particular facts at issue were not within the Form\u2019s scope.<\/p>\n

                    \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 BCC also argued that it was entitled to coverage as an Additional Named Insured to the same extent as a Named Insured, because the \u201cextent of its interest\u201d in the \u201cCovered Property\u201d included items such as rental losses and soft costs such as \u201cinterest on money borrowed to finance construction\u201d of the \u201cCovered Property.\u201d The Court rejected this argument as well, and rejected any notion that the policy definitions at issue were ambiguous. The policy clearly defined \u201cCovered Property\u201d to mean \u201cPermanent Works\u201d and \u201cTemporary Works\u201d and, if an insured\u2019s \u201cfinancial interest\u201d in these categories were intended to include rents and soft costs, the Special Time Element Coverage Form would be wholly unnecessary.<\/p>\n

                    \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Finally, the district court rejected BCC\u2019s argument that Travelers\u2019 course of conduct, including payment of the advance, entitled it to coverage. While estoppel may prevent an insurer from relying on a policy defense, it cannot create coverage where none exists in the first place.<\/p>\n

                    \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 BCC then appealed the district court\u2019s decision. In June 2025, nearly ten years after the collapse which set the entire controversy in motion, the Eighth Circuit affirmed the district court\u2019s decision in favor of Travelers.<\/p>\n

                    \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Eighth Circuit rejected BCC\u2019s invitation to equate the terms \u201cAdditional Named Insured\u201d and \u201cNamed Insured,\u201d because to do so would render the policy\u2019s definition of \u201cAdditional Named Insured\u201d meaningless. It also rejected BCC\u2019s argument that the policy\u2019s definition of \u201cAdditional Named Insured\u201d should be expanded to mean an \u201cadditional<\/em> \u2018Named Insured\u2019\u201d based on guidance from the International Risk Management Institute, Inc. (\u201cIRMI\u201d). That guidance provides: \u201can \u2018Additional Named Insured\u2019 \u2018would have the same rights and responsibilities as an entity named as an insured in the policy declarations (other than those rights and responsibilities reserved to the first named insured.\u2019\u201d However, IRMI\u2019s guidance goes on to explain that the term \u201c\u2019Additional Named Insured\u201d \u201chas not acquired a uniformly agreed upon meaning within the insurance industry and often does not include those same rights and responsibilities.\u201d The appellate court rejected BCC\u2019s argument that the policy was ambiguous and, even if it were, IRMI\u2019s guidance would not clear it up.<\/p>\n

                    \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Eighth Circuit also rejected BCC\u2019s argument that the Builders\u2019 Risk Special Time Element Coverage Form should not be construed to afford coverage only for Blanton, because the Form is tailored to address risks that BCC\u2014and not Blanton\u2014faced in undertaking the project:<\/p>\n

                    We acknowledge the possibility that BCC, and perhaps even Travelers, anticipated that BCC would be covered for lost rental income and soft costs. However, under Missouri law, the Policy \u201cmust be enforced as written when its language is clear and unambiguous.\u201d *** And the Policy\u2019s language is clear and unambiguous: BCC is an \u201cAdditional Named Insured,\u201d an \u201cAdditional Named Insured\u201d is distinct from a \u201cNamed Insured,\u201d and an \u201cAdditional Named Insured\u201d is not covered for lost rental value and soft costs. As the district court said, we \u201cmust enforce the contract before [us], not the contract [BCC] wishes had been signed.\u201d<\/p>\n

                    Takeaways<\/em><\/strong><\/p>\n

                    \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Builder\u2019s risk insurance is \u201cfirst-party\u201d coverage that protects against risks of loss of or damage to property. So perhaps it is not surprising that builder\u2019s risk coverage forms often start from the presumption that the owner<\/em> of the insured property is the one purchasing the coverage, and therefore will be the \u201cNamed Insured\u201d to which the policy\u2019s \u201cyou\u201d-s and \u201cyour\u201d-s will refer. However, in construction contracting, it is not uncommon for contractors to procure builder\u2019s risk coverage, pursuant to contractual obligations to obtain and maintain such insurance, and to receive reimbursement for the cost through the contract price. Often, the question of who procures the coverage comes down to whether the project owner or the contractor can obtain a better deal on policy premiums, rather than on closely parsing the policy\u2019s terms and definitions.<\/p>\n

                    \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Such cost savings quickly can be dwarfed by the occurrence of an uncovered loss, when a policy\u2019s forms and coverage extensions are not sized-to-fit the distinct risk patterns of the several insureds involved in a project. As the BCC Partners<\/em> case illustrates, it is crucial for lenders, owners, contractors, and their insurance brokers, to double- and triple-check that the policy offered by an insurer actually affords the coverage intended and required by the construction loan and the general contract. It should go without saying that indemnity rights in a construction loan or general contract may be worth very little in the event an owner or contractor fails to procure the insurance covering those promises. Recall in BCC Partners<\/em>, BCC obtained a $7,200,000 arbitration award against Blanton, and shortly thereafter Blanton filed for bankruptcy protection. Without adequate insurance, such awards or judgments are often not collectible.<\/p>\n

                    \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Finally, it should be noted that BCC argued on appeal:<\/p>\n

                    If the District Court’s interpretation is upheld, it will create massive turmoil with respect to on-going Projects currently covered by Builder’s Risk Insurance Policies, and will lead to lenders and developers purchasing these policies rather than reimbursing the builders\/contractors for acquiring the builder’s risk insurance.<\/p>\n

                    The Eighth Circuit did not address BCC\u2019s prediction of \u201cmassive turmoil,\u201d because it was concerned only with the language of the Travelers policy before it. Lenders, owners, and contractors do have an opportunity to avoid any such bedlam, however. They (and their insurance brokers) should confirm that the scope of their builder\u2019s risk coverages are as intended and contractually required. Correcting any coverage gaps should be relatively straight forward, but it must be done before a loss occurs.<\/p>\n

                    \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Setting aside Shakespeare to embrace the Kafkaesque, remember this when reviewing your policy: Absent policy language to the contrary, you are not \u201cyou\u201d and your coverage is not \u201cyour\u201d coverage<\/u><\/strong>\u2014unless your name is shown on the policy\u2019s declarations. Expectations for coverage must be reconciled with actual policy language. Contracts may allocate responsibility for procuring insurance, but only the policy itself defines what is covered, and for whom.<\/p>\n

                    Announcements<\/u><\/strong><\/p>\n

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                    Fabyanske, Westra, Hart and Thomson, PA <\/strong>has once again been recognized as one of \u201cThe Top 50 Construction Law Firms\u201d\u2122 <\/strong>by\u00a0Construction Executive,<\/a>\u00a0<\/strong>a leading construction industry magazine for construction firms, being the only firm in Minnesota in the Top 50. For more information click here. <\/a><\/strong><\/p>\n

                    Fabyanske, Westra, Hart & Thomson, P.A. <\/strong>has been ranked as a Band 1 Construction Law Firm in Minnesota <\/strong>by the well-recognized Chambers <\/strong>professional rating service.<\/p>\n

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                    \n

                    <\/a><\/p>\n

                    [1]<\/a> \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 140 F.4th 465 (8th Cir. 2025). The discussion in this Briefing Paper also draws from the district court\u2019s memorandum order, and appellate briefs submitted by the the parties. See BCC Partners, LLC v. Travelers Prop. Cas. Co. of Am.<\/em>, 2024 WL 1050117 (E.D. Mo. March 11, 2024); Appellant\u2019s Br., 2024 WL 2885030 (May 31, 2024); Appellee\u2019s Br., 2024 WL 3744819 (August 1, 2024).<\/h6>\n
                    This discussion is generalized in nature and should not be considered a substitute for professional advice. \u00a9 2025 FWH&T.<\/em><\/h6>\n","protected":false},"excerpt":{"rendered":"

                    By Matthew G. Nelson \u00a0Matt is a member of the firm\u2019s Construction Law Department. He can be reached at 612.359.7611 or mnelson@fwhtlaw.com Introduction \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 So, what really is in a name? The tragic\u2026<\/p>\n","protected":false},"author":8,"featured_media":3517,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[8,7,45],"tags":[],"class_list":["post-5400","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-announcements","category-briefing-papers","category-matthew-g-nelson"],"acf":[],"yoast_head":"\nWhat\u2019s In A Name? \u201cYour\u201d Coverage Extensions, That\u2019s What. - Fabyanske, Westra, Hart & Thomson<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.fwhtlaw.com\/blog\/2025\/08\/01\/whats-in-a-name-your-coverage-extensions-thats-what\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"What\u2019s In A Name? \u201cYour\u201d Coverage Extensions, That\u2019s What. - Fabyanske, Westra, Hart & Thomson\" \/>\n<meta property=\"og:description\" content=\"By Matthew G. Nelson \u00a0Matt is a member of the firm\u2019s Construction Law Department. He can be reached at 612.359.7611 or mnelson@fwhtlaw.com Introduction \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 So, what really is in a name? 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