E-Alert: Second Circuit Court of Appeals Denies Coverage for Pure Mental Injury Under “Bodily Injury” Definition

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On February 8, 2018, the United States Court of Appeals for the Second Circuit affirmed a District Court decision holding that, under New York law, the definition of “bodily injury” does not include purely mental injury. Village of Old Westbury v. America Alternative Insurance Corp., 2018 U.S. App. LEXIS 3177 (2d Cir. 2018).