Community Renewal Team, Inc. v. United States Liability Insurance, 128 Conn. App. 174

Arrowood seeks equitable subrogation against United States Liability Insurance for defense costs paid in underlying Roman v. Bristol matter.
Roman, an employee of Community Renewal Team, sued the City of Bristol for injuries from a Pine Lake Challenge Course event; Bristol's liability insurer declined to defend.
Arrowood settled Roman's claim for $700,000.
Community sued United States Liability Insurance for breach of the policy; Arrowood was substituted as plaintiff.
The trial court granted the insurer's summary judgment, holding no duty to defend based on an athletic activity exclusion; Arrowood appealed.
The central issue is whether the athletic activity exclusion unambiguously precludes defense of Roman's claims; the court affirms the trial court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the exclusion for athletic activity unambiguously bar defense of Roman's claims?	Arrowood contends the exclusion is ambiguous and could cover more.	United States Liability asserts the exclusion clearly excludes athletic activity.	Yes, exclusion unambiguously excludes the claims; no duty to defend.

Clinch v. Generali-U.S. Branch, 110 Conn.App. 29 (2008) (duty to defend based on underlying allegations; ambiguity analysis guidance)
Community Action for Greater Middlesex County, Inc. v. American Alliance Ins. Co., 254 Conn. 387 (2000) (duty to defend determined by complaint allegations)
Hartford Casualty Ins. Co. v. Litchfield Mutual Fire Ins. Co., 274 Conn. 457 (2005) (duty to defend measured by coverage of alleged injury)
Northrop v. Allstate Ins. Co., 247 Conn. 242 (1998) (policy terms interpreted in context; ambiguity rules)
Gazo v. Stamford, 255 Conn. 245 (2001) (dictionary meanings do not alone create ambiguity; context controls)
Grayned v. Rockford, 408 U.S. 104 (1972) (language cannot guarantee mathematical certainty; context matters)