Trigger of Coverage
We are aware of only one appellate court decision that has adopted the manifestation trigger of coverage for bodily injuries in the context of third party liability insurance. In
Eagle-Picher Industries v. Liberty Mut. Ins. Co., 682 F. 2d 12 (1st Cir.1982), the United States Court of Appeals for the First Circuit concluded on the evidence before it that the injury resulting from inhalation of asbestos fibers did not “occur” until the symptoms of the disease asbestosis had manifested themselves. The asbestos manufacturer had no insurance prior to 1968, the period when most of the exposure took place. The manufacturer’s CGL insurance coverage began when the number of claims began accelerating.
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