Steven Ryan is a member of the Insurance Law Practice Group. His practice focuses on insurance coverage litigation. Prior to joining Halloran & Sage he worked at a boutique insurance coverage firm.
Steven has extensive experience in first-party and third-party personal and commercial policy coverage disputes. He also represents and advises several Fortune 500 insurance carriers in complex litigation related to coverage disputes, bad faith, unfair insurance practice claims, arson and fraud investigations and prosecuting declaratory judgment actions at both the trial and appellate levels. In addition, Steven has extensive experience with handling complex litigation matters, subrogation and recovery actions, and maritime and admiralty claims in federal court.
Steven is routinely called upon to advise clients in the early stages of claim investigations to reduce and/or eliminate extra contractual exposure.
He provides coverage opinions on all personal lines of insurance, excess policies, maritime policies and commercial policies including builder's risk, surety, professional liability, employers liability policies as well as excess/surplus policies. Steven has handled appeals involving coverage before the Connecticut Appellate Court and Connecticut Supreme Court. Steven has also litigated cases in Rhode Island and Massachusetts. He has also conducted claim investigations in Florida, North Carolina, Rhode Island, New York, and Massachusetts. He also represents and counsels carriers in regulatory matters before the Connecticut Insurance Department. Steven has tried numerous jury and bench trials to verdict.
Steven has extensive experience in the examination of suspicious/fraudulent commercial and personal lines claims including arson. He has also acted as a liaison between his carriers and local law enforcement investigation involving insurance fraud.
Steven also represents towns and municipalities against general and professional liability claims. Steven also defends law enforcement officers against civil rights claims. Steven counsels municipalities, Boards of Educations and town councils regarding issues involving risk management.
Steven has authored numerous articles and given seminars on a multitude of issues concerning the insurance industry. He is routinely called upon to train claim representatives and special investigators regarding the analysis of suspicious and fraudulent claims.
Steven is a former member of the Glastonbury Town Council, Glastonbury Town Plan and Zoning Commission, Glastonbury HumanRelations Commission and the Manchester Housing Authority.
As an Eagle Scout, Steven is an avid supporter of the Boy Scouts of America.
Nationwide v. Pasiak: Continuing to Broadly Construe “Arising Out Of” Contained in Policy Exclusions
By Steven B. Ryan & Elizabeth O'Donnell, 04/11/2016
Steven Ryan Presents at the CBA Insurance Coverage 101 Seminar
Steven is an avid runner and enjoys doing half marathons throughout the year. Mr. Ryan is also a little league softball coach.
Representative Matters: Victory Obtained for Landowner/Landlord; In the matter of O' Connor v. Glasgow, Halloran & Sage obtained summary judgment in favor of its client, Glasgow LLC, after comprehensive briefing by their counsel, Steven B. Ryan and Andrea N. Moffitt, and argument by Ms. Moffitt. The plaintiff allegedly slipped and fell in a parking lot during a snowstorm, claiming that the landlord had been negligent in the maintenance of the property. At the time of the plaintiff's alleged injury, a court-appointed receiver had been put in place. The court found that the receiver held sole possession, custody and control of the premises at the time of the loss, and the plaintiff failed to produce any evidence upon which a reasonable fact-finder could conclude that Glasgow LLC was in possession, custody or control of the premises under applicable law.; Client Defended Against Extracontractual Claims; In Michael Spencer v. Edward Boucher, et al., HHB-CV14-6027775-S, the Connecticut Superior Court granted Hartford Financial Services Group, Inc.'s ( The Hartford ) motion to strike a count against it for alleged violations of Connecticut's Unfair Trade Practices Act ( CUTPA ) and Connecticut Unfair Insurance Practices Act ( CUIPA ). In Spencer, the plaintiff commenced an action against Hartford's insureds, Edward Boucher and Ann Boucher, as a result of a motor vehicle accident in which the plaintiffs' motorcycle sustained property damage. The Hartford moved to strike the only count against it, alleging violations of CUTPA/CUIPA based upon the argument that the plaintiff cannot bring suit against the carrier prior to a judicial determination of its insured's liability. The court agreed and granted The Hartford's motion to strike. By doing so, the court upheld and reaffirmed the precedence set forth in Carford v. Empire Fire & Marine Insurance Company, 94 Conn. App. 41 (2006) in that the right to assert a private cause of action for CUIPA violations through CUTPA does not extend to third party's absent, subrogation or a judicial determination of the insured's liability. Id. at 53.; The court found that Carford is directly applicable to the present case and remains good and binding law, thereby granting The Hartford's motion to strike. The Hartford was represented by Steven B. Ryan.; Summary Judgment Obtained in Dram Shop Coverage Matter: Montpelier Insurance Company v. Boku, LLC, et al.; In the matter of Montpelier Insurance Company v. Boku, LLC, et al., Halloran & Sage obtained summary judgment in favor of the firm's client, Montpelier U.S. Insurance Company ( Montpelier ) in a declaratory judgment action against its insureds, Boku, LLC ( Boku ), Renata Zak ( Zak ) and Enrique Figueroa ( Figueroa ), operators of a bar/restaurant in West Haven, Connecticut.; Montpelier insured the defendants, Boku, Zak, and Figueroa, under a commercial general liability policy (the Policy ). The defendant, Eric Jennings ( Jennings ), commenced an action against Montpelier's insureds for personal injuries he sustained, including multiple gunshot wounds, liver laceration, right interior-superior iliac spine fracture, right apical pneumothorax and pain and suffering. Jennings alleged that Boku, through its backers or permittees, Zak and Figueora, served alcoholic beverages to Hugh Suggs and Robert Gallishaw while each was intoxicated, in violation of Connecticut General Statutes 30-102 (Dram Shop Act). Jennings alleges that as a result of their intoxication, Suggs and Gallishaw shot Jennings causing his personal injuries and damages.; Montpelier commenced a declaratory judgment action in the United States District Court for the District of Connecticut seeking a declaration that it did not have a duty to defend or indemnify Boku, Zak, or Figueroa as to third-party liability claims. Montpelier argued that the underlying complaint did not allege bodily injury caused by an occurrence, as that term was defined by the Policy. In addition, Montpelier sought a declaration that the Policy specifically excluded coverage based upon the assault and battery exclusion.; Montpelier ultimately moved for summary judgment on these grounds. The District Court concluded that the underlying complaint did not allege sufficient facts from which the court could conclude whether the shootings were accidental or intentional. The court further noted that there was evidence in the record that the shootings were intentional but constrained by the vagueness of the Complaint... the shooting could thus possibly fall within the scope of an ' occurrence' as defined by the Policy. Id. at *6.; Next, the District Court analyzed the assault and battery exclusion. This exclusion provided that there was no coverage for bodily injury or personal injury arising out of assault or battery or out of any act or omission in connection with the prevention or suppression of such acts, including the failure to warn, train, or supervise, whether caused by at the instigation or direction of the insured, his employees, patrons, or any other person. Id. at *7. The District court concluded that, given the natural ordinary meaning of the exclusion, it is clear that the parties intended to exclude coverage for damages stemming from an assault and battery or any acts or omissions relating to the prevention or suppression of such assaults and batteries. In so holding, the District Court emphasized that the assault and battery endorsement clearly states this exclusion changes the policy and warns the insured that in consideration of the premium charge the enumerated exclusions ' shall apply to this policy.' Id. The District Court further noted that the assault and battery exclusions have been extensively litigated in Connecticut courts and are routinely held to be unambiguous. Id. at *9.; The District Court granted Montpelier's Motion for Summary Judgment. In so doing, the District Court rejected Jennings' argument that the expected or intended injury exclusion was ambiguous. Accordingly, Montpelier did not have a duty to defend or indemnify Boku, Zak or Figueroa in the underling action. Montpelier U.S. Insurance Company was represented by Steven B. Ryan.; Victory Obtained on Behalf of Municipal Client; Steven B. Ryan recently participated in a successful defense of the Town of West Hartford and its employee. The case involved an individual who was allegedly struck by a broom that fell from the luggage compartment while she was a passenger on the Town's bus. Her claims included the operator's failure to keep a proper lookout, failure to properly operate the bus and failure to inspect the bus to prevent such items from striking passengers. After two days of trial the jury returned a verdict in favor of the Town and its employee.; Robert Nelson and Peggy Nelson; In re: Robert Nelson and Peggy Nelson No. 3:04cv777 (JVA) Attorney Ryan represented Middlesex Mutual Assurance Company as subrogee for Jeffrey Lord ( Mr. Lord ) in a limitation of liability action commenced by the plaintiffs for a fire that damaged several vessels including Mr. Lord's vessel( The Hammerhead ). Attorney Ryan successfully petitioned the United States District Court for the District of Connecticut under the prevailing maritime laws to allow Middlesex to file an admiralty claim outside of the time allowed to file such a claim. The court sided with Attorney Ryan's client as a result of the inequitable conduct of the plaintiffs in providing notice to the public as to the time in which to file said claim against the plaintiffs.; Attorney Ryan Obtains a Favorable Result for a Firm Client After Litigating the Matter in Three Separate States; In the matter of Nautilus Insurance Company v. Michael Gherlone, et al, Halloran & Sage successfully obtained summary judgment in favor of the firm's client, Nautilus Insurance Company ( Nautilus ), in a declaratory judgment action involving a commercial general liability policy ( the Policy ) issued to its insureds, Friendship Utilities, Inc. ( Friendship Utilities ) and P&P Quickset ( P&P ). By way of background, Nautilus insured the defendants, Friendship Utilities and P&P under a commercial general liability policy. Michael Gherlone ( Gherlone ) commenced an action against Nautilus' insureds, Friendship Utilities and P&P and a Third Party Eagle Leasing Corp. ( Eagle Leasing ) for personal injuries sustained as a result of a fall down a set of stairs attached to a construction trailer. Eagle Leasing also asserted a liability claim against Nautilus' insured Friendship Utilities.; Nautilus commenced a declaratory judgment action in the United States District Court for the Eastern District of Massachusetts seeking a declaration that did not have a duty to defend or indemnify Friendship Utilities and P&P as to the liability claims being made by Gherlone and Eagle Leasing against them. Nautilus argued that the loss was excluded under the Workers' Compensation Exclusion and Injury to Employees Exclusion for any injury to an employee. Nautilus further argued that the Policy defined auto to include the trailer and therefore the loss was excluded by the Auto Exclusion as Gherlone's injuries were sustained as a result of his ingress/egress from a trailer.; Nautilus was able to obtain judgment against P&P and Eagle Leasing in the United States District Court for the District of Massachusetts. Halloran & Sage appeared before the United States Bankruptcy Court for the District of Rhode Island to obtain relief from the automatic bankruptcy stay as the defendant, Friendship Utilities, had filed for bankruptcy at the time of the commencement of the declaratory judgment action. Halloran & Sage was successful in obtaining relief from the automatic bankruptcy stay and subsequently obtained judgment against Friendship Utilities in the United States District Court for the District of Massachusetts. Thereafter, the matter was transferred to the United States District Court for the District of Connecticut, the third state where this matter was litigated.; Nautilus moved for summary judgment on the basis that Massachusetts had already ruled that Nautilus did not have a duty to defend or indemnify Friendship Utilities, P&P and/or Eagle Leasing Company under the Policy. In addition, Nautilus argued that the loss arose out of the use of an automobile and therefore coverage was excluded by the Auto Exclusion. Lastly, Nautilus argued that because Gherlone was employed by P&P, the Workers' Compensation Exclusion and Injury to Employees Exclusion operated a bar coverage. The court (Hall, J.) sided with Nautilus and granted summary judgment on the basis there was no issue of material fact. Therefore, in granting summary judgment, the court ruled that Nautilus did not have a duty to defend or indemnify Friendship Utilities and P&P against the liability claims being made in the underlying lawsuit brought by Gherlone and Eagle Leasing. Nautilus Insurance Company was represented by Steven Ryan.; Vale Properties LLC v. All American Environmental Services LLC, No. 085004885S, 2010 WL 3342188 (Conn. Super. Ct. July 28, 2010) (Marano, J.).; The trial court granted summary judgment in favor of our client, Nautilus Insurance Company, finding that the policy did not list the defendant All American Environmental Services, LLC as an additional insured under the commercial general liability policy and, therefore, no liability coverage was afforded for the claims being made by the plaintiff.; Empire Fire Marine & Ins. v. Lang, et al., 655 F.Supp.2d 150 (D. Conn. 2009).; The United States District Court granted summary judgment for the plaintiff carrier as the subject policy's use exclusion clearly and unambiguously barred coverage for losses arising out of the use of a rental vehicle regardless of who was operating the vehicle holding that the loss stemmed from construction that occurred prior to the inspection date of the Policy and thus excluded under the Policy. The court concluded that the use exclusion applied to both the renter of the vehicle and the operator of the vehicle regardless of who was operating.; Juan v. Lancer, et al., No. LLI-CV-07-5002597-S, 2011 WL 4447269 (Conn. Super. Sept. 9, 2011).; The trial court granted summary judgment in favor of our client Scottsdale Insurance Company reforming the excess automobile policy of insurance to correct a scrivener's error which mistakenly provided uninsured motorist coverage when the carrier did not intend to sell and the insured did not intend to purchase such coverage even when the reformation was made after a motor vehicle accident in which the plaintiff sought uninsured motorist coverage under the Policy.; Chestnut Investment LLC v. Nautilus Ins. Co., et al., No. CV-11-6020077-S, 2012 WL 310761 (Conn. Super. Ct. Jan. 6, 2012).; The Connecticut Superior Court dismissed the plaintiff's claims for bad faith and statutory unfair insurance and trade practices claims against our client Nautilus Insurance Company finding that the plaintiff's complaint failed to state legally sufficient claims.; Nautilus Ins. Co. v. Leyman Watson, et al.; Nautilus Ins. Co. v. Leyman Watson, et al., 3:11-CV-01061-SRU. The United States District Court for the District of Connecticut granted our client and Nautilus Insurance Company's Motion for Summary Judgment in a declaratory judgment action holding that Nautilus did not have a duty to defend or indemnify its insured in an underlying state court action.; H & S Obtains Summary Judgment in Commercial General Liability Matter, Nautilus Ins. Co. v. Leyman Watson, et al.; In the matter of Nautilus Ins. Co. v. Leyman Watson, et al., Halloran & Sage successfully obtained summary judgment in favor of the firm's client, Nautilus Insurance Company ( Nautilus ) in a declaratory judgment action involving a commercial general liability policy ( the Policy ) issued to its insureds, Luongo Construction & Development LLC ( Luongo Construction ).; By way of background, Nautilus insured the defendant, Luongo Construction, under a commercial general liability policy ( the Policy ). Luongo Construction's managing member, Michael Luongo ( Luongo ), was also an insured under the Policy. Leyman Watson ( Watson ) commenced an action against Nautilus's insured, Luongo Construction, amongst others, for personal injuries sustained as a result of a fall down a set of stairs that were allegedly constructed and/or repaired by Luongo Construction. The owners of the premises where the stairs were located, Tracy Rappa ( Rappa ) and Joanne Sardo ( Sardo ), commenced a third party complaint against Luongo Construction and Luongo asserting a breach of contract and common law indemnification stemming from the construction or repairs to the outside deck or stairs on which Watson sustained personal injury.; Nautilus commenced a declaratory judgment action in the U.S. District Court for the District of Connecticut seeking a declaration that it did not have a duty to defend or indemnify Luongo Construction as to the third party claims being made by Sardo, Rappa and Watson. Nautilus argued that Rappa and Sardo's third party complaint being asserted against its insured did not allege property damage or bodily injury caused by an occurrence as the term was defined by the Policy. Secondly, Nautilus also sought a declaration that the policy provided coverage for Luongo Construction, not Wallingford Construction Company LLC (a predecessor company started by Luongo) and, therefore, any conduct by Michael Luongo in regard to any business transactions with Sardo and Rappa was only with respect to the business dealings with Wallingford Construction LLC, not Luongo Construction. Nautilus also sought a declaration that any liability claims were excluded by the professional services construction management exclusion. Finally, Nautilus sought a declaration that the liability claims were excluded under an endorsement which excluded bodily injury or property damage arising out of your work that commenced prior to the inception date of the policy.; Nautilus moved for summary judgment on the basis that the claims being made by Sardo and Rappa, for breach of contract and common law indemnification, did not constitute an occurrence under the Policy, that the stairs were not built by the named insured (because Luongo was not acting in furtherance of the business of Luongo Construction), and that the subject stairs were built prior to the inception of the policy. During discovery Nautilus established that the stairs were not built by Luongo Construction nor Luongo's former company, Wallingford Construction. The Court (Underhill, J.) sided with Nautilus and granted the summary judgment in favor of Nautilus Ins. Co. on the basis that there is no issue of material fact that the stairs were built prior to the inception of the policy. Therefore, in granting summary judgment, the court ruled that Nautilus did not have a duty to defend and/or indemnify Michael Luongo and/or Luongo Construction & Development LLC in the underlying lawsuit brought by Leyman Watson. Nautilus Ins. Co. was represented by Steven Ryan and Meg Reid.; Court Permits Insurer to Pursue Declaratory Judgment Action to Establish Right of its Insured to Additional Insured Status; In a declaratory judgment action, the Halloran & Sage Insurance Law Group recently obtained a holding protecting a carrier's right to immediately pursue an action against another carrier to obtain additional insured coverage, rather than having to wait until the end of an underlying case. In the case of Travelers Property Casualty Company of America v. Continental Casualty Company, a case pending in the Connecticut Superior Court, Travelers sought a declaration that Continental had wrongfully failed to defend Travelers' insured because the insured was also an additional insured on the Continental policy. Continental moved to strike the declaratory judgment action, asserting that only the insured, and not Travelers, could bring such an action. Judge Peck of the Connecticut Superior Court issued a lengthy decision denying Continental's motion and holding that Travelers did have the right to pursue such an action. This decision is significant, since it provides support for the idea that where a carrier is being injured by another carrier's refusal to defend its insured, the injured carrier can immediately seek a remedy by directly suing the other carrier in a declaratory judgment action.; Travelers Property Casualty Company of America was represented by Steven Ryan of Halloran & Sage's Insurance Law Group.; Zulick v. Patrons Mutual Insurance Co. 287 Conn. 367 (2008); Roy v. Metropolitan Property and Casualty Insurance Company, 98 Conn. App. 528 (2006)