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ARTICLE · 19 JANUARY 2026

Insured Versus Insured Exclusion Defeats Coverage For Class Action Filed By Former Director

In a win for Wiley's client, the United States District Court for the District of Wyoming, applying Wyoming law, held that an insured versus insured exclusion barred coverage for an entire class action proceeding brought by an insured's former director ...

United StatesLitigation, Mediation & Arbitration

In a win for Wiley's client, the United States District Court for the District of Wyoming, applying Wyoming law, held that an insured versus insured ("IvI") exclusion barred coverage for an entire class action proceeding brought by an insured's former director against the insured and various other former directors and officers. Tri County Tel. Ass'n, Inc. v. Twin City Fire Ins. Co., No. 24-CV-274-KHR (D. Wyo. Jan. 12, 2026).

One of the insured's former directors and his wife (with whom he shared his membership interest) sued the insured telephone cooperative and various other former directors and officers in both his individual capacity and as a representative of a class of over 800 members. The suit alleged that a merger transaction undervalued the cooperative and sold it for less than it was worth. After more than four years of litigation, the insured prevailed on summary judgment. The insured sought a defense under its directors and officers liability policy, but

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