2016 Wisconsin Insurance Law Year in Review
The insurance recovery team at Quarles & Brady continually reviews emerging trends and changes in insurance coverage litigation. In 2016, Wisconsin courts were again active in the insurance coverage arena. Noteworthy decisions this year addressed (1) insurers’ duty to defend; (2) the “integrated products” exclusion; (3) the impact of other applicable insurance coverage; (4) when employees act within or outside the “course of employment;” (5) volitional acts; (6) builder’s risk insurance; (7) life insurance for strangers; (8) banker’s bond coverage for guarantee agreements; and (9) copyright infringement. Below are summaries of the key decisions.
1. Insurers’ Duty to Defend
Marks v. Houston Casualty Co., 2016 WI 53, 369 Wis. 2d 547, 881 N.W.2d 309
Water Well Solutions Service Group, Inc. v. Consolidated Ins. Co., 2016 WI 54, 369 Wis. 2d 607, 881 N.W.2d 285
A cornerstone of duty to defend law is the “four corners” rule: that whether an insurer has a duty to defend depends solely on a comparison between two documents: the complaint and the insurance policy. If any allegation of the complaint would, if proven, trigger coverage under the policy then the insurer must defend. Two companion cases, decided by the Supreme Court on the same day, provided clarification on this important principle.
In Marks, the insured, David Marks, served as the trustee for two irrevocable trusts. The trusts had ownership interests in various entities and as a result Marks served on the boards of these entities. Marks (along with others) was named a defendant in a series of lawsuits involving these entities. He was insured by an E&O policy that provided coverage in Marks' capacity as a Trustee of the named insured, which were the irrevocable trusts. The policy contained an exclusion barring coverage for “liability arising out of the Insured's services and/or capacity as . . . an officer, director, partner trustee or employee of a business enterprise not named in the Declarations . . .” Though the other entities were not named in the policy, Marks sought a defense on the rationale that he was serving on the other entities' boards by virtue of his position as a trustee of the insured trusts. He further argued that the exclusion did not apply because exclusions should not be considered for purposes of determining whether the duty to defend was triggered, citing earlier case law that arguably compelled such a result. The Supreme Court ruled that this in fact was not the law; the duty to defend is to be assessed by comparing the complaint to the entire policy, not just the coverage grant. The Court also rejected any suggestion that the rule should be different when the insurer refuses to defend (as opposed to defending under a reservation of rights while contesting defense and coverage) and to the extent prior case law suggested otherwise, it was overruled.
While Marks primarily concerned what portion of the policy was relevant to the duty to defend, the Water Well decision involved the other pertinent document: the complaint. In Water Well, the insured argued that the court should be able to go outside the complaint to ascertain true facts to show the duty to defend was triggered. The insured was a contractor hired to perform work on an existing well, including removal of a pump and installation of a new pump. The new pump came unthreaded and fell to the bottom of the well, allegedly because of the insured's negligent installation. So far as the complaint was concerned, the alleged damages were limited to the pump that had been installed, which implicated the “your work” and “your product” exclusions. The insured argued that true facts outside the complaint showed that damages extended beyond the damage to the pump, challenging the long standing “four corners” rule that the duty to defend was based solely on what was alleged on the face of the complaint. Notwithstanding the fact that some 31 other jurisdictions had recognized a potential exception to the rule, the Supreme Court was swayed by the long standing nature of the rule in Wisconsin, noting its ease of application and that it generally operated to the benefit of insureds.
While the obvious takeaway from these cases is that, for better or worse, a very strict and literal “four corners” rule is alive and well in Wisconsin, there are some less obvious but perhaps no less important takeaways as well. Marks makes it important for those insureds serving in a fiduciary relationship on behalf of related entities to ensure that they receive coverage in the event they are sued in a claim involving the separate entities.
As a separate takeaway, Water Well puts insureds in the position of needing to take proactive steps to hold the plaintiff to its pleadings. For example, if there really were property damage caused by the insured's negligent installation going beyond the pump it installed, the insured certainly would not want to be in the position of being held liable for damages that would be insured but for an incomplete or ambiguously-worded complaint. On this point, motions, such as a motion to make more definite statement in the complaint, may well have insurance implications.
On the plus side, Water Well suggested in a footnote that coverage could exist even where there was no duty to defend (parting company with a number of jurisdictions on this issue). And both cases seemingly upheld the principle that an insurer that breaches the duty to defend is subject to harsh consequences, and that those consequences may include an estoppel to challenge coverage, and even policy limits. As insurers continue to challenge this doctrine, these two cases may end up providing helpful ammunition to policyholders, despite the unfavorable outcomes.
2. Integrated Products Exclusion
Wisconsin Pharmacal Company LLC v. Nebraska Cultures of California, Inc. et al, 2016 WI 72, 367 Wis. 2d 221, 876 N.W.2d 72
In our complex economy, manufacturers regularly incorporate their products into other manufacturers’ products. With this common practice in mind, the Wisconsin Supreme Court addressed whether adding an incorrect or defective component part into an integrated product results in property damage under a general liability policy when that component cannot be removed or replaced and renders the integrated product useless. In finding no coverage, the Court applied the economic loss doctrine’s so-called “integrated system analysis” to determine whether covered property damage existed under a general liability policy.
Wisconsin Pharmacal Company LLC v. Nebraska Cultures of California, Inc. et al, 2016 WI 72, 367 Wis. 2d 221, 876 N.W.2d 72, involved a contract between a pharmacy wholesaler (Wisconsin Pharmacal) and a drug manufacturer (NMS) for the manufacture of a dietary supplement product. NMS procured a necessary ingredient for the supplement from another party (Jeneil). After manufacturing and selling the finished supplement, it was soon discovered that the supplement contained the wrong ingredient from Jeneil, could not be used, and had to be destroyed. Pharmacal sued Nebraska Cultures, Jeneil, and their respective general liability insurers, seeking coverage under standard commercial general liability policies; the policies covered “property damage” caused by an “occurrence,” (defined as an “accident”).
The Wisconsin Supreme Court, in a slim three justice majority decision (two justices recused themselves), held there was no property damage caused by an occurrence and further held that the policy’s “impaired property” and “your product” exclusions barred coverage.
In finding no coverage, the court incorporated a tort concept – the economic loss doctrine’s integrated system analysis–to decide what constitutes “property damage” under a general liability policy. Under the economic loss doctrine’s integrated system analysis if a component damages or renders an integrated system or product useless, a claimant cannot recover in tort for such damages. With limited exceptions, the doctrine is intended to maintain separation between the law of tort and contract, and only allows a tort recovery for damage that a defective component causes to “other” property. In an integrated system, however, there can be no “other” property damage when a defective component harms the integrated system.
The Wisconsin Pharmacal court held that since the damaged supplement was comprised of many ingredients, it was an integrated product so that no property damage could result when one bad constituent renders the entire integrated product useless. The Court reasoned that where a defective component cannot be separated there is no damage to other property and therefore no property damage under a general liability policy. Significantly, the Court also found no loss of use—the other component of property damage in a general liability policy—and held that loss of use in a general liability policy did not mean total loss of the underlying product.
The Wisconsin Supreme Court also decided that no “occurrence” existed under these facts. The Court held that Jeneil’s act of accidentally providing the wrong ingredient did not automatically rise to the level of an occurrence. Instead, some subsequent event or condition that arose out of the breach of contract must give rise to property damage. The Court cited Am. Family Mut. Ins. Co. v. American Girl, 2004 WI 2, ¶48, 268 Wis. 2d 16, 673 N.W.2d 65, as an example, of where something more needs to happen beyond initial negligence in order to trigger an occurrence. In American Girl, negligent engineering of a building later gave rise to soil settlement and property damage. Here, the Court found that Jeneil negligently providing the wrong ingredient did not give rise, in and of itself, to an occurrence causing property damage.
Wisconsin Pharmacal is a troubling decision for insureds—particularly for suppliers to manufacturers—as it potentially eliminates general liability coverage for damages claimed due to a defect in a component product. A supplier whose defective goods are placed in an integrated system may not have coverage if the customer sues the supplier alleging that the defect caused damage to the overall product. Insureds may now need to consider endorsements or specialized insurance policies—such as performance bonds and product recall insurance—to address this potential risk.
Haley v. Kolbe & Kolbe Millwork Co., Inc., 2016 WL 4487807 (W.D. Wis., August 25, 2016)
Land O’Lakes, Inc. v. Ratajczak, Case No. 14-C-4388 (E.D. Wis., August 24, 2016)
The Wisconsin Supreme Court’s Wisconsin Pharmacal holding later directly influenced two federal district court holdings in 2016, both of which found no coverage in the face of a defective component causing harm to an integrated product or system. In the case of Haley v. Kolbe & Kolbe Millwork Co., the district court decided in the context of allegedly defective replacement windows that leaked and caused water damage to adjacent building walls that no coverage existed under an integrated system analysis. There, the court held that the windows were part of the integrated system and therefore damage to other surrounding property was not property damage within the meaning of a general liability policy. Similarly, in Land O’Lakes, Inc. v. Ratajczak, the federal district court decided in the context of an adulterated whey protein product that there was no property damage where the adulterated ingredient mixed into the integrated whey protein product rendering it less useful and effective.
3. Impact of Other Applicable Insurance Coverage
Burgraff v. Menard, Inc., 2016 WI 11, 367 Wis. 2d 50, 875 N.W.2d 596.
The focus of this case was on whether Menards' self-insured retention (“SIR”) qualified as “other applicable liability insurance” under the “other insurance” clause in plaintiff's auto policy, such that plaintiff's insurer (Millers First) was only required to pay a pro rata portion of the loss, leaving Menards to pick up the rest.
Menards argued that its SIR was not “other applicable liability insurance” and, in any event, should be treated as excess coverage pursuant to an “other insurance” provision. The Supreme Court rejected this argument, relying on Hillegass v. Landwehr, 176 Wis. 2d 76 (1993), for the proposition that an SIR constitutes “other applicable liability insurance.”
But this did not end the Court's inquiry. After the trial court granted Millers First's motion for partial summary judgment, limiting Millers First's indemnity exposure to one-sixth of any verdict or settlement, Millers First settled with plaintiff for a sum certain in exchange for a release “fully discharg[ing] Millers First . . . and one-sixth of any liability that [defendant] may have to [plaintiff].” Millers First then withdrew its defense. In doing so, Millers First was held to have breached its duty to defend. Under the terms of the policy, Millers First was obligated to defend defendant until Millers First had paid the policy “limits of liability,” not Millers First's “maximum exposure,” i.e., the pro rata share of any verdict or judgment. This breach, the Court held precluded Miller's first from seeking contribution from Menards. The importance of this holding to insureds is that a carrier that breaches its duty to defend will likely not have any right of contribution, or even set off for amounts the insured receives from other carriers.
Dufour v. Progressive Classic Ins. Co., 2016 WI 69, 370 Wis. 2d 313, 881 N.W.2d 678.
Dufour dealt with the contours of the “made whole” doctrine which says that an insurer cannot be reimbursed by a tortfeaser for amounts it pays to the insured until the insured is “made whole.”
Dufour, the insured of Dairyland Insurance Company, sustained personal injuries and property damage in a motorcycle accident caused by a third party tortfeasor. The tortfeasor's insurer paid Dufour its $100,000 liability policy limit, and Dairyland paid its $100,000 underinsured policy limit. Dairyland also paid Dufour $15,000 for his damaged motorcycle under another provision in its policy. Dairyland then sought and obtained subrogation from the tortfeasor's insurer for the $15,000 paid for property damages. Dufour demanded Dairyland pay him the funds it obtained on its subrogation claim, and Dairyland refused. Dufour then sued Dairyland for breach of contract and bad faith.
The primary issue before the Supreme Court was whether Dairyland was entitled to retain the subrogated funds from the tortfeasor's insurer, despite its insured not being fully compensated for his injuries. The issue was whether the “made whole” doctrine applied to preclude Dairyland from retaining a subrogation recovery for property damage when the insured had not been made whole for his personal injury. Based on a weighing of equities, the court found that the insurer was able to keep the subrogation recovery.
The Court reasoned that Dairyland had paid Dufour for all he bargained for under the policy for personal injury, Dufour had priority in settling with the tortfeasor's insurer, and if Dairyland had not proceeded on its subrogation claim, which it could have chosen to do, Dufour would have had no access to additional funds from the tortfeasor's insurer in the first place.
4. What “Course of Employment” Means in Connection with Coverage For Employees
J.K.J. v. Polk County Sheriff’s Dept., Case No. 15-CV-428-WMC, 2016 WL 6956662 (W.D. Wis. Nov. 28, 2016)
A correctional officer at the Polk County Jail engaged in sexual contact with two detainees. When those detainees filed lawsuits, the correctional officer sought coverage under a Public Entity Liability Policy issued to Polk County. The policy provided coverage for personal injury caused by sexual molestation, but it only covered employees “while acting within the scope of their employment or authority.”
The Court agreed with the insurer that the correctional officer was acting outside the scope of employment and therefore was not entitled to coverage under Polk County’s policy. Judge Conley determined that courts must focus not on whether an employee’s position (i.e., one of authority over inmates) facilitated the sexual contact, but whether the employee in some way intended for his/her conduct to serve the employer. Here, the correctional officer admitted that the sexual contact was purely for his own gratification, which doomed his coverage argument under the Court’s analysis.
Doe v. County of Milwaukee, Case No. 14-CV-200-JPS, 2016 WL 7017375 (E.D. Wis. Dec. 1, 2016)
Interestingly, just a few days after the J.K.J. decision, another federal judge in Wisconsin reached the same result, albeit through a very different route. A correctional officer at the Milwaukee County Jail allegedly engaged in sexual contact with several detainees. One of the detainees sued, and the correctional officer sought coverage under a policy issued to Milwaukee County providing coverage similar the one at issue in the Polk County case.
In stark contrast to Judge Conley’s decision in the Polk County case, Judge Stadtmueller found Wisconsin law too conflicting to say for certain that the sexual contact was outside the scope of employment. Namely, a jury could reasonably infer that the sexual contact stemmed from and was made possible by the employment. Ultimately coverage was denied under another exclusion (a “penal statute exclusion”) but the important point for business insurance purposes is that coverage based on “course of employment” remains open to debate.
5. Expansion of the Volitional Acts Doctrine
Jones v. Baecker, Case No. 15AP235, 2016 WL 7471577 (Wis. Ct. App. Dec. 28, 2016)
We have written in the past about the Wisconsin Supreme Court’s expansion of the volitional acts doctrine, an anti-policyholder approach that threatens to eliminate insurance coverage for a whole host of negligence claims. This year, the Wisconsin Court of Appeals waded into the area, to the further detriment of policyholders.
When prospective tenants contacted a landlord about renting an apartment, the landlord’s comments suggested that he would not rent to them because of their family status (i.e., too many people for the space) and/or their race, both of which could violate state and federal law. The prospective tenants sued the landlord, who tendered the lawsuit to his general liability insurer. The insurer denied coverage because the policy only covered “occurrences” (i.e., accidents), and the lawsuit alleged intentional discrimination by the landlord. The trial court ordered the insurer to defend the lawsuit because even if the lawsuit alleged intentional discrimination, it did not allege that the damage from that conduct (i.e., the prospective tenants’ emotional distress) was intentional.
Citing the Wisconsin Supreme Court’s development of the volitional acts doctrine over the past 20 years, the Court of Appeals overruled the trial court, stating “The key takeaway is this: volitional acts that produce a desired event are not 'accidents,' even if they produce unexpected and unforeseen results and even if they are precipitated by one or more negligent acts.” The Court denied coverage under this reasoning even though the landlord was unaware it might be illegal to refuse to rent to large families (much less that doing so would cause the prospective tenants emotional distress).
As an aside, such conduct is seemingly no more “volitional” than a driver who misses a stop sign and inadvertently causes a collision, but the Court suggested that the driver in that case would get insurance because there was no intent to cause a collision, while the discriminating landlord could not access coverage because he intentionally denied housing to prospective tenants. While the potential for arbitrary line-drawing seems high and will lead to unpredictable results for policyholders, one way for courts to limit application of volitional acts would be based on whether the “accident” stemmed from the insureds’ mistaken knowledge or belief as to the plaintiff’s legal rights. An insured repo company who repossesses a car based on a mistaken belief as to ownership does not have coverage; an insured physician who volitionally amputates the wrong limb of a patient does. A thin distinction to be sure but that seems to be the current law.
6. Scope of Builder’s Risk Insurance
Fontana Builders, Inc. v. Assurance Co. of America, 2016 WI 52, 369 Wis. 2d 495, 882 N.W.2d 398
First-party property insurance covers loss to property owned by the insured and damages sustained directly by the insured (as opposed to liability insurance which covers third-party claims against an insured). There are various types of first party property insurance. Two are builders risk insurance which covers damage occurring during construction and homeowners insurance which as most of us know covers damage to a finished residence. The interplay between the two can present difficult questions, as was the subject of the Supreme Court's decision in Fontana Builders. The case is particularly relevant to the construction industry.
In the Fontana Builders case, a fire destroyed portions of a home. The home had been completed, but both the builder and the owner had interests in the home. Assurance, the issuer of the builder’s risk policy, argued that its coverage had terminated prior to the fire when the occupant purchased a homeowner’s policy from another insurer, relying on a provision of the builder’s risk policy stating coverage terminates “when permanent property insurance applies.”
The Court found the termination provision ambiguous because it failed to state to whom or what “permanent property insurance” must “apply” to terminate coverage, i.e., whether such insurance must “apply” to the builder and the builder’s insurable interest in the structure or whether it might apply more broadly to anyone having any insurable interest in the property, such as the occupant.
Having found the provision ambiguous, the Court construed it against Assurance and in favor of the builder, holding that the homeowner’s policy issued to the occupant was insufficient to terminate coverage under the builder’s risk policy, particularly given that the occupant and builder had separate and different insurable interests in the home.
Significantly, the Court unanimously held that the interpretation of an ambiguous policy provision is a question of law for the court to decide, not a question of fact for the jury, notwithstanding that the court must consider extrinsic evidence (e.g., the occupant’s homeowner’s policy) to resolve the ambiguity. As long as the ambiguity relates to the application of the provision to specific facts and not a dispute concerning the parties’ differing understandings regarding the meaning of the provision at the time they entered into the contract, such a question is a question of law.
7. Collecting Insurance on the Death of a Stranger
Sun Life Assurance Co. of Canada v. U.S. Bank Nat'l Ass'n, 839 F.3d 654 (7th Cir. 2016)
Last year, U.S. Bank won a very good bet on the death of wealthy octogenarian, Charles Margolin. The Seventh Circuit affirmed the award of $6 million in proceeds under a policy issued by Sun Life Assurance Company of Canada, despite the fact that the policy was an illegal gambling contract.
In every state, including Wisconsin, it is illegal to own an insurance policy on someone else's life unless the policyholder has an insurable interest in the life. The Wisconsin legislature however has assigned the risk of these illegal policies to the insurer. Wisconsin Statute section 631.07(4) allows courts to order the proceeds of policies where the policyholder lacks an insurable interest be paid to someone other than the policy designee who is equitably entitled to it.
U.S. Bank purchased the Sun Life policy on Mr. Margolin's life as part of a bundle of life insurance policies on behalf of another investor. The Seventh Circuit affirmed that, even though the policy was an illegal gambling contract under Wis. Stat. § 895.055, § 631.07(4) controlled and required Sun Life to pay the policy proceeds to U.S. Bank. The latter section trumped because of a third law, § 600.12(2), which states that where the insurance code conflicts with another section, the insurance code governs. The Court also rejected Sun Life's argument that § 631.07 legalized gambling, something forbidden under Article IV, section 24 of the Wisconsin Constitution. The Court clarified that insuring the life of a stranger is still illegal; § 631.07 only changes the remedy. Finally, the Court affirmed a finding of bad faith because Sun Life, which had refused to pay until it investigated the validity of the policy, had no reasonable basis for delaying payment.
8. No Coverage for Forged USDA Assignment Guarantee Agreements
Citizens Bank Holding Inc. v. Atlantic Specialty Insurance Co., Case No, 15-cv-00782 (E.D. Wis. Nov. 16, 2016)
In 2013, banks nationwide lost over $175 million to a massive fraud scheme perpetrated by First Farmers Financial LLC. Under the scheme, First Farmers Financial forged certain documents relied on in the USDA Rural Development Business & Industry Guaranteed Loan Program. This program encourages lending to rural business by having the USDA guarantee portions of the loans which are then sold on a secondary market. Under the program, an approved lender makes a loan, the USDA guarantees the loan, and the lender sells the guaranteed portion of the loan to an investor. The guaranteed portion of the loan is assigned to the investor by a USDA Assignment Guarantee Agreement (“AGA”). One such investor was Citizens Bank Holding, Inc. Citizens purchased $15 million in USDA guaranteed loans as part of a loan pool administered by Pennant Management Inc. Unfortunately, the underlying loans were those forged by First Farmers Financial who fabricated the borrowers and forged the USDA Assignment Guarantee Agreements.
Citizens Bank had purchased insurance coverage for forgeries under a Financial Institution Bond issued by Atlantic Specialty Insurance Co. Citizens claimed coverage under multiple insuring agreements within the Bond. Insuring agreement part D covered losses resulting directly from forgeries on “letters of credit,” among other documents, and insuring agreement part E covered losses resulting directly from Citizens' good faith reliance on “corporate or personal guarantees” or “certificated securities.” The Bond expressly defined letter of credit, guarantee, and certificated securities.
Atlantic denied coverage under insuring agreements D and E claiming that Citizens' loss did not “result directly” from the forged AGAs but from the fact that the underlying loans did not exist. To Atlantic, it was immaterial that the forged AGAs were the operative document to transfer Citizens interest in the loans and Citizens relied on them exclusively, or that if valid, they would have carried the full faith and credit of the United States, requiring the USDA to pay back the loans. Atlantic also accused Citizens of failing to follow sound business practices by not adequately investigating the underlying loans. Finally, Atlantic asserted that the USDA Assignment Guarantee Agreements did not qualify as a letter of credit, corporate or personal guarantee, or certificated security.
The District Court sided with Atlantic on the narrow basis that the documents did not qualify as letters of credit, corporate or personal guarantees, or certificated securities as defined by the Bond. The Court found that while the AGAs qualified as guarantees, they were not personal or corporate, and, as guarantees could not reasonably qualify under another bond definition. The Court did not reach the issues of whether the losses resulted directly from the AGAs or Citizens' business practices. The case is significant as an example of the very narrow permutation that exists in theft and fidelity policies and how such permutation may affect coverage.
9. Copyright Infringement
Design Basics LLC v. Fox Cities Construction Corp, 2016 WL 5485185 (E.D. Wis. Feb. 9, 2016)
Finally, one Wisconsin federal court case addressed advertising injury coverage for copyright infringement claims. The insured, a home builder, allegedly infringed on the various copyrighted home drawings. Prior to suit and before the issuance of the general liability policy at issue, the copyright owner sent a cease and desist letter to the insured. The owner later sued to recover the profits that the insured had obtained from building homes with the copyrighted materials.
After suit was filed, the insurer sought to exclude coverage based upon three grounds: (1) that the advertising injury coverage was not triggered; (2) that a “prior publication” exclusion barred coverage; and (3) that the “known loss” doctrine precluded coverage.
In arguing that advertising injury coverage was not triggered, the carrier conceded that while the copyrighted materials were advertised within the meaning of the policy, there was no causal connection between those advertisements and the claimed injuries which werethe lost profits from homes built using the copyrighted materials. The carrier argued that such profits were at best indirectly related and not causally related to the advertising because the insured had to take the additional step of building the infringing homes after advertising them. The Court held that at least a portion of the injuries complained of were caused by the advertising, itself, therefore triggering coverage.
Even though advertising injury coverage was triggered, the Court agreed with the insurer that two exclusions barred coverage. One was the “prior publication” exclusion which precluded coverage for liability arising out of copyrighted materials first published before the policy period. The Court held that because the copyrighted materials were first advertised and published years before the policy period, the exclusion excluded all coverage. The Court rejected an argument that because some materials were also published during the policy period, later publication nullified the exclusion’s application, reasoning that to hold otherwise would render the exclusion illusory.
Along similar lines, the Court also applied the “known loss” doctrine to preclude coverage, holding that the insured knew about potential liability or loss already occurring before purchasing the policy, in part by receiving a cease and desist letter from the copyright owner. The Court rejected the concept that the known loss doctrine only applies in cases where there is knowledge of actual versus potential liability, holding that an insured’s knowledge of potential liability connotes knowledge of a risk to be insured against and is sufficient to warrant application of the known loss doctrine.
For any questions, please contact Keith Bruett at (414) email@example.com, Pat Nolan at (414) firstname.lastname@example.org, Patrick Murphy at (414) email@example.com, Brandon Gutschow at (414) firstname.lastname@example.org, Alex Shortridge at (414) email@example.com Joseph Poehlmann at (414) 277-5763/ firstname.lastname@example.org, or your local Quarles & Brady attorney.