Recently, an Ohio FC&S reader wondered, more specificallyworried, whether liability-based theories involving progressivedamage could be applied in first-party property loss situations.That is not quite the way that the subscriber put his question, butthat is what he was getting at.

What does that mean? Progressive losses are when damage toinsured property occurs continuously over a period of time,stretching into two or more insurance policy periods. In theliability arena, various coverage trigger theories have developed,such as the manifestation theory (when the damage first becomes orshould become evident) and the triple-trigger theory (each singleevent leading to the ultimate damage is another manifestation ofdamage, triggering all policies that may have been issued to theinsured during the period leading to the ultimate damage). Thesetheories developed out of asbestos litigation and other cases inwhich bodily injury could be argued to have occurred at various(and multiple) times in the causation chain.

What about first-party property loss situations, such asthe one posed by our Ohio subscriber?

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