Daniel Ro v. Factory Mutual Insurance Company, as Subrogee of Trustees of Dartmouth College Sebastian Lim v. Factory…

Summary

The New Hampshire Supreme Court affirmed the trial court’s summary‑judgment ruling that the student plaintiffs are implied coinsureds under Dartmouth College’s fire‑insurance policy, applying the anti‑subrogation doctrine from Cambridge Mutual Fire Ins. Co. v. Crete. The Court held that the college‑student housing relationship is sufficiently analogous to a landlord‑tenant lease to invoke the Sutton doctrine, and that the student handbook does not contain an express agreement that negates that doctrine.