A recent Pennsylvania ruling offers an instructive look at the difference between blanket and scheduled insurance coverage and what policyholders must do to ensure they get the coverage they think they are buying. The case, Beazley Underwriting, Ltd. v. Max & Mia Realty, LLC, 1 arose out of a dispute following a catastrophic fire at a commercial property owned by Max & Mia Realty (MMR). The central issue before the court was whether the property insurance policy at issue provided blanket coverage across multiple properties or was instead limited by scheduled values assigned to each location.
Those studying insurance coverage must understand the critical distinction between blanket and scheduled coverage. In a blanket policy, a single limit of insurance applies across multiple properties or categories of property, offering flexibility for claims that disproportionately affect one location. For example, a policyholder with a $5 million blanket limit covering three buildings could apply the full $5 million to a loss at one building, even if the other two are untouched. A scheduled policy, by contrast, assigns separate limits to each insured item or location. Suppose Building A is listed with a $1 million value, and it suffers a total loss. In that case, the most the policy will pay is $1 million, even if the policyholder has additional coverage capacity that is not allocated to the loss location.
Max & Mia Realty claimed it had purchased a blanket policy that would provide up to $7.77 million in total coverage for all insured properties, allowing that full amount to be applied to losses at any one location. This belief was based in part on communications with its insurance broker, McConkey Insurance, and on a “Statement of Values” submitted during the insurance application process that contained the phrase “Blanket Building, Contents & EDP $7,770,598.”
The business insurance proposal provided by McConkey also used the term “Blanket” to describe the building and business personal property coverage. MMR argued that its understanding, formed through broker representations and supporting documentation, was that each of its buildings and associated personal property was collectively covered up to the total policy limit, regardless of individual location values.
Beazley Underwriting, represented by its very able counsel, Greg Mast, argued that the policy was unambiguously a scheduled policy, not a blanket one. The insurer pointed to the policy’s “Scheduled Limit of Liability” endorsement, which expressly stated that liability would be limited to “100% of the individually stated value for each scheduled item of property… at the location which had the loss.”
Beazley emphasized that the policy form was labeled “A Scheduled Policy” and that the Statement of Values provided by MMR listed discrete values for each building and type of property at each location. Beazley argued that these documents left no room for ambiguity and that the coverage was capped at the specific dollar amounts listed per building and per type of property. Beazley also noted that even if MMR misunderstood the policy’s structure, the court should enforce the contract as written, without relying on external communications or subjective beliefs.
The court ultimately agreed with Beazley, granting summary judgment in its favor and holding that the policy unambiguously provided scheduled rather than blanket coverage. It found that the Scheduled Limit of Liability endorsement controlled, limiting recovery to the amounts listed for each individual location and type of property. The court dismissed MMR’s argument that the phrase “Blanket Building, Contents & EDP” in the broker-prepared Statement of Values created a blanket policy, noting that this document was not part of the policy contract itself. Moreover, the court observed that MMR had not objected to the final policy language nor sought clarification or correction before the loss occurred.
There are clear lessons for policyholders and their insurance agents. First, it is not enough to discuss “blanket coverage” informally or even to include the term in application materials or proposals. Agents should inspect the actual policy language to make certain it reflects the intent of the order to provide blanket coverage. This is especially true when dealing with excess and surplus carriers who are increasingly providing final policy forms that contradict orders. Second, policyholders should carefully review all policy endorsements and declarations, and they should confirm in writing with their broker that the issued policy conforms to their expectations. Third, if the policy includes a “Scheduled Limit of Liability” clause, that is a strong indication the policy is not blanket in nature. These clauses are showing up in many policy forms, where other portions of the policy seem to indicate that the parties were seeking a blanket policy. In short, clarity and proactive communication are essential. If blanket coverage is desired, it must be specifically negotiated, clearly documented in the final policy, and understood by all parties before any loss occurs.
The difference between a $3.4 million scheduled limit and a $7.7 million blanket limit can mean millions in unrecoverable losses. It can also lead to a claim of negligence against agents for the unrecovered amounts. Careful policy design and documentation are the best defense against that risk.
For those wishing to study this topic further, I suggest reading When Is a Policy “Blanket”? A Recent Court Decision Shows It’s Not Always Clear Cut.
Thought For The Day
“People often think they’re protected, only to find out the details tell a different story.”
—Amy Bach, Executive Director of United Policyholders
1 Beazley Underwriting, Ltd. v. Max & Mia Realty, no.3:22-cv-1404 (M.D. Penn. June 18, 2025) (See also, Max & Mia Realty’s Answer to Complaint with Affirmative Defenses and Counterclaim, and Beazley Underwriting’s Motion for Summary Judgment).
