In Reed v. Auto-Owners Ins. Co., 2008 WL 4286606 (Ga. ), the Supreme Court of Georgia determined the proper construction of a pollution exclusion clause in a commercial general liability policy.

Leslie Reed, a residential tenant, sued her landlord, Melvin Waldrop, for carbon monoxide poisoning allegedly caused by the Waldrop's failure to keep the rental house in good repair. Waldrop tendered the claim to Auto-Owners Insurance under his CGL policy, and Auto-Owners assumed Waldrop's defense under a reservation of rights.