Section 15.6 Bodily Injury

• Library: Insurance Practice 2015

Missouri has adopted an injury-in-fact trigger of coverage in bodily injury cases. In Standard Asbestos Manufacturing & Insulating Co. v. Royal Indemnity Insurance Co., Civil No. CV80-14909 (Jackson County, Mo. Cir. Ct. April 3, 1986), the insured sought a declaratory judgment in favor of a continuing trigger of insurance coverage for bodily injury claims resulting from asbestos exposure. In construing the CGL policies, Judge O’Leary of the Jackson County Circuit Court concluded that:

The policies require...