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In Am. Reliable Ins. Co. v. Addington., No. 3:21-CV-00848, __ F.Supp.3d __, 2022 U.S. Dist. LEXIS 218436, the United States District Court for the Middle District of Tennessee (the District Court) considered whether a tenant’s live-in partner and the partner’s adult son constituted a “family” in the underlying lease and, thus, were implied co-insureds under the Sutton Rule. The District Court determined that the arrangement did constitute a “family” and that the Sutton Rule barred subrogation.Continue Reading

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