The Rhode Island Supreme Court agreed that the insurer had no coverage obligations for bodily injury occurring after the policy had been canceled. Hoesen v. Lloyd's of London, 2016 R.I. LEXIS 41 (R.I. March 24, 2016). The plaintiff, Mark Van Hoesen, was seriously injured on July 23, 2012, when he fell from a deck of his house. He sued his contractor, Brian Leonard, alleging that the deck had been negligently constructed. Lloyd's, Leonard's insurer, was later named as a defendant. Lloyd's admitted it issued the policy to Leonard, but it was cancelled on August 29, 2007. Even if it had not been canceled, the policy had expired long before the injuries alleged in plaintiff's complaint occurred. Lloyd's filed a motion for summary judgment, arguing that it did not insure Leonard for plaintiff's injuries because the policy applied to bodily injury only if the bodily injury occurred during the policy period. The policy issued to Leonard was effective from March 8, 2007, to March 8, 2008. The trial court granted summary judgment to Lloyd's. On appeal, the plaintiff argued that, notwithstanding the language in the policy, it contravened a Rhode Island statute. The statute provided, "Throughout the period of registration, the contractor shall have in effect public liability and property damage insurance covering the work of that contractor . . . ." Plaintiff argued that, because the policy covered only injuries that occurred while the policy was in force, and because Lloyd's canceled the policy a few weeks after Leonard finished constructing the deck, the net result was that the policy provided almost no coverage at all, and certainly none to plaintiff. The statutorily mandated coverage was rendered a nullity if coverage could be terminated in the immediate aftermath of the work. The statute, however, imposed no duty on any insurer to provide continuing coverage after the policy period expired. Nor was it a violation of public policy to not require an insurer to provide coverage after the policy period expired or when a contractor failed to honor its obligations under the policy. Even if the injury was caused by Leonard's faulty workmanship, which occurred during the policy period, the "bodily injury" must also have occurred during the policy period for there to be coverage. Therefore, the decision of the trial court was affirmed.
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