Joe Nilan and Dan Ellerbrock recently obtained an order granting summary judgment in favor of an insurance client. The case involved two issues of first impression in North Dakota: the scope of an insured vs. insured exclusion and the policy’s requirement that a claim be based on actions taken “solely” in an insured capacity. The Court decided both questions in our favor, and held that our client had no obligation to provide coverage for the underlying litigation against the insured.