Case Explained: NATASHA URENA, Administrator of the Estate of Juliana Rodriguez Morel; DANIEL RODRIGUEZ, Administrator of the Estate of Juliana Rodriguez Morel v. TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA

Court: United States Court of Appeals for the First Circuit Filed: 2026-08-11 The First Circuit affirmed the district court’s grant of judgment on the pleadings in favor of Travelers Casualty and Surety Company of America, holding that the insurer was not liable under its Employment Practices Liability (“EPL”) endorsement to pay a default judgment entered against Mammoth Tech, Inc. for pregnancy-related discrimination claims. The court determined that the “Related Claims” provision within the policy’s overarching Liability Coverage Terms and Conditions (“LCTC”) applied to the EPL endorsement, thereby deeming the January 2021 lawsuit filed by Juliana Rodriguez Morel a “Related Claim” to her March 2019 administrative complaint. Because the earlier administrative complaint was made before the EPL policy period began in December 2020, the related claims provision backdated the “first made” date for the subsequent lawsuit to that prior time, excluding it from coverage. The court applied New Hampshire substantive law and reviewed the interpretation of the insurance policy de novo. It rejected the appellants’ argument that the EPL endorsement superseded the LCTC’s Related Claims provision, clarifying that an endorsement controls over the base policy only when the provisions are in direct conflict. The court found no such conflict because the LCTC’s related claims mechanism and the EPL endorsement’s “Prior and Pending Proceeding” exclusions operate independently to address different scenarios: the former defines when a claim is “first made,” while the latter excludes liability for losses arising from wrongful acts underlying proceedings filed before a specific prior date (December 4, 2015). The court further dismissed reliance on out-of-state precedent and arguments regarding policy ambiguity, concluding that the provisions functioned harmoniously to exclude coverage. As a result of this affirmation, the judgment on the pleadings in favor of Travelers stands, meaning the insurer has no obligation to pay the $303,592.20 judgment or associated costs awarded against Mammoth Tech, Inc. The administrators of the estate are left without recovery from the insurance policy for these specific claims. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.