The United States District Court for the District of Arizona recently held that the efficient proximate cause doctrine does not exist in Arizona and, therefore, a policy’s concurrent causation language should be given effect.

In Stankova et al. v. Metropolitan Property and Casualty Ins. Co., 2012 U.S. Dist. LEXIS 150900 (D. Ariz. Oct. 17,

For the second time in two months, the Massachusetts Supreme Judicial Court was called upon to decide whether or not property damage was covered when the damage resulted from a combination of a covered peril and an excluded peril. Once again, the court upheld the policy’s enforceable anti-concurrent causation language, finding that coverage was precluded.

The Massachusetts Supreme Judicial Court recently considered the interplay between “hidden seepage” coverage, and a “surface water” exclusion, holding that the policy’s enforceable anti-concurrent causation language made all the difference in the court’s conclusion that a loss caused by surface water seeping into a structure was excluded.

In Boazova v. Safety Insurance Company, Docket No.