TENNESSEE

Chris Brown’s Forged Receipts Preclude Insurance Recovery for Burned Down Studio

R&B artist Chris Brown, through his company Tattooed Millionaire Entertainment (TME), owned a music studio and equipment in Memphis. Brown is TME’s sole owner. After a break-in and arson damaged the studio and gear, the property insurer faced competing claims from TME (the lessor), Brown’s tenant, and Brown. Evidence showed Brown forged receipts to inflate losses. Brown admitted it at trial.

The insurer filed an interpleader to decide how to divide the insurance proceeds and argued that public policy should block paying Brown if funds might reach the fraudulent lessor (TME). The district court allowed payment to Brown’s tenant (who may not have been involved in the fraud) and ruled that Brown’s forgery barred him and his company from recovering under the policy.

The Sixth Circuit affirmed. Under Tennessee law, a joint loss payable clause allows splitting proceeds between a lessor and a tenant based on the value of their interests, as determined by the lease. The appeals court approved an allocation tied to the leasehold’s valuation, not an all-or-nothing award. It affirmed Brown’s forgery of receipts, which barred his recovery under the policy. Decision.

FLORIDA

7-Day Notice Provision in Pollution Liability Policy Enforced

A Florida gas station owner bought a claims-made-and-reported storage tank liability policy. The policy required notice “as soon as reasonably possible, but not more than seven days” after the insured became aware of a pollution condition that may lead to a claim. In 2017, inspections by the Florida Department of Environmental Protection indicated a new discharge. In August 2018, the insured’s consultant found groundwater contamination with multiple chemicals over legal limits. Despite this, the insured waited eight months (April 2019) before notifying its insurer.

The Eleventh Circuit affirmed summary judgment. The insurer had no duty to defend or indemnify because the insured knew of the pollution condition by August 2018 but waited eight months to report it — far outside the seven-day window. Since strict reporting requirements in claims-made-and-reported policies are enforced, late notice alone defeated coverage. Decision.

NEW YORK

Rental Mobile Home Not Part of Insured Premises

Homeowners purchased first-party property coverage for their primary residence. On the same parcel sat a separate mobile home that they rented to others. After the mobile home burned down, they claimed coverage under their homeowners’ policy. The insurer denied the claim.

The trial court granted summary judgment to the insurer, which the appeals court affirmed. The policy unambiguously covered only the residence and related private structures at the insured premises listed on the declarations. The mobile home was not the insureds’ residence, had its own separate address, road access, and utilities, and was not listed on the declarations or the related private structures endorsement (which listed only a pole barn). Because nothing in the policy identified the mobile home as part of the insured premises, there was no coverage and no triable issue of fact. Decision.

MONTANA

Montana Shortens Time to Bring Contract and Construction Claims

Key changes to the statute of limitations have gone into effect in Montana:

Written contracts: Statute of limitations reduced from eight years to six years.

Construction/land surveying: Statute of repose reduced from 10 years to six years.

Sixth-year injury grace: If an injury occurs during the sixth year after completion/survey, suit may be filed within one year of the injury;

No changes to other limits: five years for unwritten contracts; three years for other non-written obligations remain the same.

It applies to actions “founded on an instrument in writing” filed on or after October 1, 2025. It is not retroactive and does not apply to actions filed before October 1, 2025. Claims professionals, design professionals, and construction contractors should note the shorter time frame for bringing liability actions. Bill Text.