In St. Paul Fire & Marine Ins. Co. v. Sea Quest Int’l, Inc., 676 F. Supp. 2d 1306 (M.D. Fla. 2009), Sea Quest contracted with insured Trident to construct a yacht. Sea Quest terminated Trident prior to completion, alleging defective and untimely construction. Sea Quest sued Trident for breach of contract and negligence, obtained a judgment against Trident for the costs to repair Trident’s defective work and complete the vessel, and then sought to collect on the same from Trident’s CGL insurer, St. Paul. The federal trial court entered summary judgment for St. Paul, holding that, based on JSUB and Pozzi Windows, in the absence of any property damage beyond the insured’s faulty workmanship or defective work, there was no “property damage.”
Florida “property damage” caused by an “occurrence”
