Atlanta Gas Light Co. v. Navigators Insurance Co., 164 F.4th 1038 (7th Cir. 2026)
I. Background
Atlanta Gas Light Company and its parent (collectively, AGL) hired United States Infrastructure Corporation (USIC) to locate and mark gas lines in Georgia. USIC’s service agreement required it to procure primary and excess liability insurance, naming AGL as an additional insured. USIC carried a primary policy with Zurich and an excess policy with Navigators Insurance Company.
In 2018, USIC failed to properly mark a gas line, and a contractor struck the line, causing an explosion at a café that severely injured three people. AGL, USIC, and the injured parties participated in a pre‑suit mediation in 2019. USIC settled first, exhausting its primary policy limits. Navigators did not attend the mediation. The plaintiffs then filed suit against AGL in Georgia state court (the “underlying suits”), alleging negligence based solely on AGL’s own conduct.
