Recently, the Commonwealth Court of Pennsylvania gave
policyholders another victory in the continuing battle with
insurers over application of the "multiple trigger"
doctrine. In Pennsylvania Manufacturers' Association
Insurance Co. v. Johnson Matthey, Inc., the Commonwealth Court
held that the multiple-trigger approach – which expands the
number of policies potentially available to provide coverage for
long-tail liabilities – can be applied to claims involving
environmental contamination, rejecting another attempt by the
insurance industry to limit application of the doctrine in
Pennsylvania. Significantly, the court held that in determining
whether the multiple-trigger approach will apply, the critical
factor is whether the underlying injury involves a long latency
period between the initial exposure to the injurious condition, and
the ultimate discovery (manifestation) of the resulting injury or
damage. Although the decision arises in the context of coverage
