Supreme Court of Connecticut
Hartford Fire Ins. Co. v. Moda, LLC
January 27, 2023346 Conn. 64
Summary
The court affirmed summary judgment denying coverage for the defendants’ COVID-19-related business losses under both the package policy and the marine policy. Under Connecticut law, the package policy’s requirement of direct physical loss or damage was not satisfied by diminished inventory value, loss of use, governmental closures, or alleged viral contamination, and New York law likewise required physical harm to the insured property under the marine policy. The court did not reach the package policy’s virus exclusion because the losses were not covered in the first place.