The Fourth Circuit Court of Appeals held that an insurer had a contractual duty to defend its insured under a CGL policy in Cowan Systems, Inc. v. Harleysville Mut. Ins. Co., No. 05-2253, 2006 WL 2256518 (4th Cir. Aug. 8, 2006).

Cowan Systems, a transportation company, entered into a contract with Linens 'N Things to provide transportation. George Shaffer, who worked for Cowan, was injured in a mud lot leased by Linens 'N Things after delivering an empty trailer to the lot. He filed a personal injury lawsuit against Linens 'N Things for negligence in failing to remove ice and snow from the lot.