PRISTINE POOLS, LLC v. HARTFORD FIRE INSURANCE COMPANY, 2:24-cv-00269

Plaintiffs (Pristine Pools, LLC, et al.) sought insurance coverage from Hartford Fire Insurance Company for a state lawsuit alleging faulty workmanship.
Hartford denied its duty to defend, arguing that allegations of faulty workmanship do not constitute an "occurrence" under its policies.
The policy defined “occurrence” as “an accident, including continuous or repeated exposure to substantially the same general harmful conditions.”
Plaintiffs argued that some claims involved "consequential damage" to property beyond the contracted work, seeking coverage.
The case was decided on cross-motions for summary judgment before Judge Cathy Bissoon in the Western District of Pennsylvania.
The court applied the four-corners rule to interpret the insurance policy in light of Pennsylvania law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What is an “occurrence” under the policy?	Faulty workmanship and resulting damages qualify	Only accidental, fortuitous events do	Faulty workmanship ≠ occurrence
Duty to defend for property damage beyond work	Consequential damage to other property covered	Distinction irrelevant under binding law	No duty to defend for any such damage
Applicability of four-corners rule	Should not limit analysis to four corners	Four-corners rule applies strictly	Four-corners rule applies
Relevance of Indalex and Pottstown	These cases support broader interpretation	Circuit precedent controls, not applicable	Circuit precedent distinguishes them

Sapa Extrusions, Inc. v. Liberty Mut. Ins. Co., 939 F.3d 243 (3d Cir. 2019) (claims of faulty workmanship are not "occurrences" under CGL policies in Pennsylvania)
Specialty Surfaces Int'l, Inc. v. Cont'l Cas. Co., 609 F.3d 223 (3d Cir. 2010) (faulty workmanship allegations do not qualify as an “occurrence”)
Amer. Home Assurance Co. v. Superior Well Servs., Inc., 75 F.4th 184 (3d Cir. 2023) (property damage from failure to perform a contract in a workmanlike manner is not an “occurrence”)