Though courts are typically limited to interpretations based on the Though courts are typically limited to interpretations based on the "eight corners" of the policy and the complaint, Washington law permits courts to draw on extrinsic evidence outside those eight corners when determining the application of the duty to defend. In this case, the court turned to county records. Credit: Roxane Bay/Adobe Stock

The U.S. District Court for the Western District of Washington ruled that an insurer must defend an insured homeowner because, though the policyholder had two mailing addresses, both were on one parcel of land. The case is Homesite Ins. Co. of the Midwest v. Howell, 2023 U.S. Dist. LEXIS 230991 (W.D. Wash. 2023). 

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