A Tennessee appeals court ruled that a tenant was considered an additional insured on a landlord's policy and that the insurer had no subrogation rights against the tenant in Allstate Ins. Co. v. Watson, No. M2003-01574-COA-R3, 2005 WL 457846 (Tenn. Ct. App. Feb. 25, 2005).

Kevin Williams owned a house and leased it to Robert Watson. A fire occurred at the home, and Williams's insurer, Allstate, paid the loss. Allstate brought suit against Watson, claiming it had subrogation rights under Williams's policy. The trial court found that Allstate was entitled to subrogation against the tenant according to the following statement in the lease: “Residents are responsible for all damages to the apartment, intentional or non-intentional. Owner is to be notified of all damages and will provide repairs.” Watson appealed.