In Connecticut Insurance Guaranty Assoc. v. Fontaine, No. 17457, 2006 WL 1737380 (Conn. July 4, 2006), the Connecticut Supreme Court decided that a professional liability policy was ambiguous and that it could be construed against the Guaranty Association. The Association would stand in the place of the insurer and assume its responsibilities.

Carol Fontaine and her husband, Thomas, brought action against Thomas' physician, Michael Jimenez. The Fontaines alleged that Jimenez's medical malpractice caused bodily injury to Thomas, which resulted in Carol's loss of consortium. Jimenez was insured by PHICO Insurance Company.