Law360, “LDS Church’s 10th Circ. Win Widens Insurance Ruling Splits,” quotes Joseph R. Miele, Jr. Esq., 8-6-2026

Kaufman Dolowich’s Joseph Miele, Jr., Fort Lauderdale Partner, was recently quoted in a Law360 article addressing the Tenth Circuit’s decision in a coverage dispute that contributes to an existing split among federal courts regarding the meaning of an insurance-policy “occurrence.”

Mr. Miele characterized the decision as “inconsistent with general insurance principles,” noting that the underlying case involved multiple abuse victims and multiple incidents at different locations. He contrasted the ruling with an Eleventh Circuit decision arising from the 2018 Parkland high school shooting, where the court determined that the attack constituted a single occurrence under the policy.

He explained that, unlike the Parkland shooting—which involved a single attacker at one location over a short period—the Tenth Circuit’s decision appeared to treat the church’s alleged negligence as the sole cause of the injuries. He noted that this approach could broaden the scope of coverage under a liability policy by focusing not on the actual injury-causing event, but on conduct that may have set it in motion.

Subscribers can read the full article here: LDS Church’s 10th Circ. Win Widens Insurance Ruling Splits – Law360 UK