Supreme Court Rejects Producer Duty to Warn of Nonrenewal

Insurance Coverage / Producer Negligence

Supreme Court rejects ongoing duty of homeowners’ insurance producer to warn of nonrenewal

The plaintiffs had a long but intermittent relationship with an independent agency (The Trahan Agency) and, after a two-year gap, used that producer to place a one-year homeowners policy with National General Insurance Company. When the insurer later decided not to renew the policy, it notified the producer but no one directly informed the Deers, and the policy expired; after a subsequent loss, the plaintiffs sued both the insurer and the producer, alleging that the producer negligently failed to notify them of the impending nonrenewal and owed a continuing duty to monitor their coverage and warn them before the policy lapsed. The trial court granted summary judgment for the producer, the Appellate Court affirmed, and the Supreme Court agreed, framing “the primary issue in this certified appeal [as] whether an insurance broker has a duty to inform its clients that their homeowners insurance provider intends not to renew their insurance policy” and holding that, absent a special undertaking or special relationship, an insurance producer’s agency “ordinarily end[s] once it has procured the requested coverage,” so there is no general, ongoing common-law obligation to track renewals or relay nonrenewal decisions. Deer v. National General Ins. Co., SC 21045 (Conn. Sept. 9, 2025).