The United States District Court for the District of Colorado, applying Colorado law, has held that two tenant class actions alleging distinct improper fee practices at an apartment complex do not constitute “related claims” subject to a single limit of liability. Cardinal Group Mgmt. & Advisory, LLC v. QBE Ins. Corp., 2026 WL 1831276 (D. Colo. May 12, 2026).
The insured property manager sought coverage for two underlying lawsuits under claims-made commercial liability policies. The first lawsuit, filed during the 2021–2022 policy period, alleged that the insured failed to maintain properties in an apartment complex in a habitable condition and improperly charged tenants move-out and administrative fees. The second lawsuit, filed during the 2023–2024 policy period, alleged that the insured failed to adequately disclose trash and property tax fees charged to tenants at the same apartment complex. The insured sought a declaratory judgment that the lawsuits were not “related claims”
