Case Explained: 26a0186p.06

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-06-29 The Sixth Circuit affirmed the district court’s dismissal of Lauren Bridges’s contract and declaratory judgment claims against Maxum Indemnity Company and Landmark American Insurance Company, holding that the legal-malpractice insurance policies at issue unambiguously precluded coverage under Michigan law. Regarding the Maxum policy, the court applied the standard that insurance contracts must be enforced as written when their language is clear and unambiguous. The court found that Section VII.B. of the policy established a condition precedent requiring notice of any “potential claim” to be given during the specific “Policy Period” (May 2018 to May 2019) for subsequent actual claims to be covered under an extended reporting period. Although McKeen reported a potential claim in April 2020, this occurred after the Policy Period had expired and only within the Optional Extended Reporting Period. The court rejected the appellant’s argument that a scrivener error in the endorsement—referencing a “Supplemental” rather than “Optional” extended reporting period—created an ambiguity, ruling instead that the terms were harmonious and the notice requirement was strictly limited to the Policy Period. Regarding the Landmark policy, which functioned as excess coverage following the StarStone policy, the court applied the rule that contract interpretation is a question of law determined by plain meaning. The Landmark policy excluded claims based on wrongful acts occurring prior to its retroactive date of May 2, 2019. The underlying legal malpractice arose from McKeen’s failure to respond to motions for summary judgment in 2018, which fell outside the retroactive date and was therefore excluded. The court further held that Bridges waived any argument regarding the potential for inconsistent rulings with the StarStone policy by failing to raise it in the district court, and found no merit in the contention that interpretation of the underlying StarStone policy required a delay in adjudicating Landmark’s liability. The practical consequence is that the judgment of the United States District Court for the Eastern District of Michigan is affirmed, leaving Bridges without coverage under the Maxum or Landmark policies for her legal-malpractice claim against McKeen. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.