Court Says Condominium Owner has no Claim Against HOA Insurance Policy for Damage to Individual Unit

This case involved a dispute between a condominium owner (“Owner”), his homeowners association (“Association”), and its insurance carrier (“Insurer”) over Owner’s entitlement to make a claim for insurance proceeds from Association’s policy issued by Insurer. In 2016, Owner’s condominium unit suffered water damage as a result of a ruptured water pipe caused by renovation work being performed in another unit. Association had a commercial property insurance policy issued by Insurer which provided coverage for “direct physical loss or damage to Covered Property” caused or resulting from any covered cause of loss. Association was the only named insured identified in the policy which provided a single stated limit of liability for the building and a separately stated limit of liability for business personal property. The policy did not contain a separate stated limit of liability for the individual units.