Business Interruption Claims and September 11

March 2006

This edition of Case of the Month actually discusses two recent cases. Both deal with airlines' claims for business interruption losses following September 11, 2001, but each addresses different issues.

by Kevin Merriman
Goldberg Segalla LLP

PMA Capital Ins. Co. v. US Airways, Inc. (Va. Mar. 3, 2006)

At issue in this appeal was US Airway's claim for compensation under an all-risk manuscript property subscription policy for business interruption losses arising from the September 11 terrorist attacks. The policy provided commercial property coverage in the amount of $25 million dollars from December 1, 2000, through December 1, 2001, of which PMA Capital, as successor to one of the original subscribers, underwrote 10 percent of the coverage.

Following the terrorist attacks on the World Trade Center on September 11, the Federal Aviation Administration (FAA) issued a ground stop order, ordering all civilian aircraft to land or stay on the ground. The attack on the Pentagon resulted in the closure of Reagan National Airport, and, while other airports soon reopened, the FAA issued a temporary flight restriction that closed the air space within 25 nautical miles of Reagan National Airport. This order resulted in the closure of Reagan National Airport and restricted access to it for 2 weeks. As such, US Airways was not permitted to conduct commercial flights into or out of Reagan National Airport from September 11 to October 4, 2001.

US Airways made a claim for business interruption losses and PMA Capital Insurance denied coverage for the claim. US Airways then filed suit, seeking judgment declaring that PMA was obligated to indemnify it for the losses, damages for breach of contract, and damages for alleged bad faith. In this case, the Virginia Supreme Court considered only one issue: whether payments received by US Airways from the federal government pursuant to the Air Transportation Safety and System Stabilization Act of 2001 were recoveries under the policy's offset provision. The court concluded they were.

The policy's offset provision required that losses claimed under the policy be reduced by "[a]ll salvages, recoveries, and payments … received prior to a loss settlement…." Section 101 of the Air Transportation Safety and System Stabilization Act of 2001 states:

  • (a) In General.—Notwithstanding any other provision of law, the President shall take the following actions to compensate air carriers for losses incurred by the air carriers as a result of the terrorist attacks on the United States that occurred on September 11, 2001:

  • (2) Compensate air carriers in an aggregate amount equal to $5,000,000,000 for—

  • (A) direct losses incurred beginning on September 11, 2001, by air carriers as a result of any Federal ground stop order issued by the Secretary of Transportation or any subsequent order which continues or renews such a stoppage; and

  • (B) the incremental losses incurred beginning September 11, 2001, and ending 10 December 31, 2001, by air carriers as a direct result of such attacks.

US Airways argued that Congress did not intend for the Air Transportation Safety and System Stabilization Act of 2001 to reduce insurance proceeds, while PMA argued that the plain language of the policy required that funds received under the Air Transportation Safety and System Stabilization Act of 2001 should offset any recovery under the policy. Focusing exclusively on the term "payment" in the policy's offset provision, the trial court concluded that the term did not contemplate proceeds from federal programs. The trial court also relied on commentary by the Department of Transportation interpreting the Air Transportation Safety and System Stabilization Act of 2001 to conclude that its decision was consistent with Congressional intent.

The Virginia Supreme Court disagreed, holding that payments received by US Airways under the Air Transportation Safety and System Stabilization Act of 2001 offset recoveries under the policy. The court reasoned that, by its plain language, the Air Transportation Safety and System Stabilization Act of 2001 was designed to "compensate air carriers" for both "direct losses" as a result of "any Federal ground stop order" and "incremental losses" as a "direct result of" the September 11, 2001, terrorist attacks. The court concluded that "the federal compensation provided by the Air Transportation Safety and System Stabilization Act of 2001 was for the purpose of regaining or restoring the losses suffered by US Airways as a result of the terrorist attacks." Thus, the Air Transportation Safety and System Stabilization Act of 2001 funds were a form of "recoveries" under the policy's offset provision.

In reaching its conclusion, the court rejected arguments that commentary by the Department of Transportation evinced a different intent, and found that the trial court had considered only one of three categories of payment in the policy's offset provision—the term "payments"—in finding that the proceeds received by US Airways were not contemplated by the policy. The court observed that "recovery" is defined as "the regaining or restoration of something lost or taken away," (Black's Law Dictionary 1302 (8th ed. 2004)), and "the act of regaining or returning toward a normal or usual state" (Webster's Third New International Dictionary 1898 (1993)), which was clearly within the purview of the statute. It was error, held the court, for the trial court to rewrite the policy and make a new contract between PMA and US Airways.

Finding that the policy clearly required that Air Transportation Safety and System Stabilization Act of 2001 funds received by US Airways were to reduce its losses under the policy, and that the $310 million received by US Airways exceeded the $58 million in claimed losses and the $2.5 million potential liability of PMA under the policy, judgment was entered in favor of PMA.

United Airlines, Inc. v. Insurance Co. of the State of Pennsylvania (2nd Cir. Feb. 22, 2006)

United Airlines brought suit for coverage under its $25 million "Property Terrorism & Sabotage" insurance policy with the Insurance Company of the State of Pennsylvania, for losses it suffered as a result of the September 11, 2001, terrorist attacks on the World Trade Center and the Pentagon. It was undisputed that United's ticket office located in the World Trade Center was destroyed, and that United was entitled to coverage for lost earnings attributable to physical damage at this location; however, its facilities at Reagan National Airport did not suffer physical damage as a result of the attack on the Pentagon. Therefore, the issue on this appeal was whether United could recover for its lost earnings caused by the national disruption of flight service and the government's temporary shutdown of the airport, in the absence of physical damage to the property or an adjacent premises.

The court held that, because United could not show that the lost earnings resulted from physical damage to its property or from physical damage to an adjacent property, the losses were not covered by the policy.

United's policy provided:

  • [ISOP] will indemnify [United] for property damage, loss of gross earnings, and extra expense in excess of the Deductible [as later defined] ... resulting from [terrorism], and any ensuing fire damage, damage from looting, or other damage caused by an act of a lawfully constituted authority for the purpose of suppressing or minimizing the consequences of [an incident of terrorism].

Another section of the policy dealing specifically with loss of gross earnings provided that the policy "insures against loss resulting directly from the necessary interruption of business caused by damage to or destruction of [United's] Insured Locations resulting from Terrorism." The policy then stated that "[t]his section is specifically extended to cover a situation when access to the Insured Locations is prohibited by order of civil authority as a direct result of damage to adjacent premises."

To recover gross earnings under the policy, the court concluded that United would be required to show that the business interruption resulted from either: (1) physical damage to property at the insured location (airport); or (2) an order of civil authority as a result of physical damage to property adjacent to the insured location (Pentagon). United's property at the airport was not physically damaged, and, as such, it could not recover for "damage to or destruction of the Insured Locations resulting from Terrorism."

Nor could it recover under the civil authority clause of that section of the policy for loss of gross earnings during the government's suspension of flights into and out of the airport. The court held that to do so, United must show that it was denied access to its "locations" at the airport "as a direct result of damage to adjacent premises." Though there was some dispute whether the airport was an "adjacent premises," the court did not reach this issue, since United could not also demonstrate that the airport was shut down "as a direct result of damage to" the Pentagon.

In this regard, the court found that there was a temporary halt of flights into and out of the airport before the Pentagon was struck. Moreover, the government's subsequent decision to halt operations at the airport was based on fear of future attacks, which was evidenced by the airport's reopening only when it was able to comply with safety standards. The court found that the reopening had nothing to do with repairing, mitigating, or responding to damage. The court concluded, therefore, that the interruption to United's business was not the "direct result" of damage to adjacent premises.

United argued that the first section of the policy, which it referred to as a "suppression damages clause," provided a separate basis to recover loss of gross earnings without having to establish that the business interruption resulted from either physical damage to property at the insured location, or an order of civil authority as a direct result of physical damage to adjacent premises. The clause provided:

  • [ISOP] will indemnify [United] for property damage, loss of gross earnings, and extra expense in excess of the Deductible [as later defined] ... resulting from [terrorism], and any ensuing fire damage, damage from looting, or other damage caused by an act of a lawfully constituted authority for the purpose of suppressing or minimizing the consequences of [an incident of terrorism].

United argued that this clause afforded separate coverage—that when the government closed the airport to thwart possible airborne attacks, United suffered "other damage caused by an act of a lawfully constituted authority for the purpose of suppressing or minimizing the consequences of [an incident of terrorism]."

The court rejected United's interpretation of the policy, concluding that the section, when read in the context of the policy as a whole, was merely to serve as an introduction to the policy, and that the scope of damages it could recover for business interruption must be determined by cross-referencing that section of the policy specifically dealing with loss of gross earnings.

The court reasoned that the policy set forth only three types of damages covered: physical damage, loss of gross earnings, and extra expenses. The section then listed various triggering events that may cause one or more of the these damages, including fire, looting, or acts of a "lawfully constituted authority for the purpose of suppressing or minimizing the consequences of terrorism." Thus, the court concluded:

  • the policy states that whenever there is an act of … terrorism—or terrorism-caused fire, terrorism-caused looting, or an "act of a lawfully constituted authority for the purpose of suppressing or minimizing the consequences of [an incident of terrorism]"—then United will be indemnified for its physical damages, loss of gross earnings, and extra expenses resulting therefrom. It does not provide that if there is an "act of a lawfully constituted authority for the purpose of suppressing or minimizing the consequences of [an incident of terrorism]," United is entitled to indemnity for any and all resulting loss, including loss of gross earnings, however caused and unlimited by the remaining terms of the contract.

In a footnote, the court observed that United had received federal aid under the Air Transportation Safety and System Stabilization Act of 2001, but that it still had unreimbursed losses.


Opinions expressed in Expert Commentary articles are those of the author and are not necessarily held by the author’s employer or IRMI. This article does not purport to provide legal, accounting, or other professional advice or opinion. If such advice is needed, consult with your attorney, accountant, or other qualified adviser.