A Louisiana court of appeals ruled that a commercial umbrella liability policy did not “drop down” to provide coverage when the primary insurer was insolvent in Domingue v. Legion Indemnity Co., No. 05-580, 2006 WL 20016 (La. App. 3 Cir. Jan. 4, 2006).

Ronald Domingue, while riding his bicycle, was struck and killed by a vehicle operated by John Ard. The vehicle was owned by Louisiana Motors, for which Ard was an independent contractor. He used the vehicle with the permission of Louisiana Motors.