Christian Dichter & Sluga is honored to be included by U.S. News – Best Lawyers in the 2022 Edition of their Best Law Firms rankings. The Best Law Firms rankings are based on a rigorous evaluation process, and Best Lawyers is the oldest peer-reviewed publication in the legal profession. CDS Law is one of only...
INSIGHTS
Arizona Supreme Court settles key UM/UIM stacking dispute with important implications for insurers and policyholders
By: Nathan Andrews On July 6, 2026, the Arizona Supreme Court held that multiple individuals who jointly purchase multiple insurance policies from the same insurer constitute “one insured” for the purposes of the anti-stacking provisions of A.R.S. § 20-259.01(H). Thus, an insurance company may prohibit a claimant from stacking multiple policies jointly purchased by multiple individuals...
2024 CDS Super Lawyers Announced
As a boutique insurance coverage and litigation firm, Christian, Dichter & Sluga has worked hard to earn the respect of its peers in the Southwest. With each recognition of a lawyer in our firm, we appreciate the validation of the efforts of our team to provide the best possible resolution to our clients while working...
Case Alert – Medina v. Est. of Cody
CDS Helps Client Win Landmark Tribal Rights Case The Arizona Court of Appeals issued an opinion in Medina v. Est. of Cody, No. 1 CA-CV 22-0709, 2023 WL 6470727, at *1 (Ariz. Ct. App. Oct. 5, 2023), in which Gena L. Sluga, managing partner at Christian Dichter and Sluga appeared on behalf of Sentry Insurance...
Case Alert – Franklin v. CSAA Gen. Ins. Co.
Arizona Supreme Court Issues New Opinion on Policy Stacking By: Asha Sebastian, Esq. On July 28, 2023, the Arizona Supreme Court issued its Opinion in Franklin v. CSAA Gen. Ins. Co., CV-22-0266-CQ, 2023 WL 4833792, holding as follows: 1. In order to prevent insureds from intra-policy stacking, insurers must comply with the anti-stacking provision...
Gena L. Sluga recognized in Super Lawyers Top 25 Women Arizona List
CDS Shareholder Gena L. Sluga has been recognized in the 2023 Super Lawyers Top 25 Women Arizona Super Lawyers List! Super Lawyers is a rating service of outstanding lawyers from more than 70 practice areas who have attained a high degree of peer recognition and professional achievement. The selection process includes independent research, peer nominations, and...
Christian Dichter & Sluga, P.C. Ranked in 2023 “Best Law Firms”
U.S. News & World Report and Best Lawyers®, for the 13th consecutive year, announce the U.S. News – Best Lawyers® “Best Law Firms” rankings. Christian Dichter & Sluga, P.C. has been ranked in the 2023 U.S. News – Best Lawyers® “Best Law Firms” list nationally in 1 practice areas and regionally in 7 practice areas. Firms included in the 2023 U.S. News...
CDS welcomes Amanda Taylor as Partner
Christian Dichter & Sluga is pleased to announce that Amanda Taylor has accepted its offer of partnership. Amanda will continue to work with our clients and associates on matters involving insurance coverage and claim management. Says CDS Partner, Doug Christian: “Amanda brings several valuable skills to our partnership. Like others she is joining in our...
Gena L. Sluga recognized by Chambers USA
Christian Dichter & Sluga, P.C. is proud to announce that Chambers USA has once again recognized the firm in its 2022 annual rankings of the world’s leading law firms and lawyers. Shareholder and Managing Partner, Gena L. Sluga, has been recognized in our core practice area – Insurance for the fourth consecutive year. CDS is one...
Best Law Firms: Christian Dichter & Sluga Honored by U.S. News – Best Lawyers™
Christian Dichter & Sluga is honored to be included by U.S. News – Best Lawyers in the 2022 Edition of their Best Law Firms rankings. The Best Law Firms rankings are based on a rigorous evaluation process, and Best Lawyers is the oldest peer-reviewed publication in the legal profession. CDS Law is one of only...
Partner J.P. Harrington Bisceglia Elected to AADC Board of Directors
Christian Dichter & Sluga is honored to announce that J.P. Harrington Bisceglia has been elected to the Board of Directors of the Arizona Association of Defense Counsel (AADC). The AADC is a non-profit organization established in April 1965 and is comprised of defense attorneys from all backgrounds who practice primarily in civil defense litigation. The AADC is...
CKDJS obtains Nevada Supreme Court win upholding exclusion in $1M umbrella policy
Filippo Sciarratta v. Foremost Insurance Company Grand Rapids Michigan, et al., No. 79604, 137 Nev. Adv. Op. 32 (Jul. 8, 2021). Summary. Christian, Kravitz, Dichter, Johnson & Sluga (“CKDJS”) recently secured a victory for their insurer clients before the Supreme Court of Nevada in an appeal regarding the validity of an exclusion for damages “payable to...
CDS shareholder Gena Sluga honored by Chambers USA
Christian Dichter & Sluga, P.C. is proud to announce that Chambers USA 2021 (a publication of Chambers of Partners) has once again recognized the firm in its annual rankings of the world’s leading law firms and lawyers. In the latest publication, the firm and shareholders Gena L. Sluga and Alison R. Christian were recognized in our core practice area...
Nevada Supreme Court: Insurer’s Right to Seek Reimbursement of Defense Costs
On March 11, 2021, the Supreme Court of Nevada issued an order answering a certified question posed by the United States Court of Appeals for the Ninth Circuit regarding the insurer’s right to seek reimbursement from the insured for defense costs associated with uncovered claims. Specifically, the question was: Is an insurer entitled to reimbursement...
Gena L. Sluga recognized in Top 100 Lawyers in Arizona for 2021!
CDS Shareholder Gena L. Sluga has been recognized in the Top Lawyers in Arizona for 2021! This prestigious group of lawyers is chosen by AZ Business Magazine’s editorial team in collaboration with industry experts. The attorneys are selected from a pool of more than 2,000 of the state’s most talented and successful attorneys. Selections are based on each...
CDS obtains Ninth Circuit win regarding coverage for a $1,500,000 Morris Agreement
Christian Dichter & Sluga recently secured victory for a client insurance company before the Ninth Circuit in an appeal over coverage for a $1,500,000 Morris Agreement. Appellant, as the assignee of a putative insured, alleged claims for breach of contract, waiver/estoppel and insurance bad faith arising from the insurer’s denial of adjustment of an automobile...
CDS shareholder Gena Sluga continues her active involvement with the Federation of Defense & Corporate Counsel for 2020-2021.
CDS shareholders Alison R. Christian and Gena L. Sluga continue their active involvement with the Federation of Defense & Corporate Counsel for 2020-2021. Ms. Christian has been appointed to serve as Vice-Chair of the Law Practice Management Section. She will also serve as Vice-Chair of various Committees, including the Insurance Industry Institute, Professional Women’s Forum,...
Christian Dichter & Sluga honored by Arizona Women Lawyers Association
Christian Dichter & Sluga is a proud recipient of the Arizona Women Lawyers Association’s 2020 All in for Women Award! While this award typically recognizes law firms that have all female attorneys as members, this year’s award was particularly significant in that it also included law firms that help to further the mission of the...
Nevada Supreme Court: Insurer that breaches duty to defend is responsible for consequential damages, but not an expired judgment against insured
On September 20th, the Supreme Court of Nevada issued an order answering certified questions posed by the United States Court of Appeals for the Ninth Circuit directed at the vitality and application of its recent ruling in Century Surety Co. v. Andrew, 134 Nev., Adv. Op. 100, 432 P.3d 180 (2018). In Century Surety, the Court...
New Mexico Appeals Court: No Coverage but Maybe Bad Faith
New Mexico remains firmly in the column of states where the tort of bad faith may be “untethered” from coverage. Haygood was shot by Cordova in, or near, Cordova’s parked car. The car was uninsured and Haywood presented an uninsured motorist claim to his insurer, USAA. The adjuster recommended paying the claim as related to...
Gena Sluga is chair of the FDCC Insurance Coverage Section
CDS shareholder Gena Sluga has been selected as chair of the Federation of Defense & Corporate Counsel (FDCC) Insurance Coverage Section for 2019-2020. Ms. Sluga’s FDCC involvement has also included serving as program chair of the 2017 Insurance Industry Institute, co-chair of the Professional Women’s Forum, vice chair of the Extra-Contractual Liability Section, and program chair of...
Arizona district court says shooting not an occurrence under homeowners policy
Rhonda Cerny shot Craig Cerny in the chest with a .22 caliber revolver from a distance of five to ten feet. Rhonda pleaded guilty to Aggravated Assault. The factual basis for her plea agreement was that “she recklessly caused serious physical injury to C. Cerny by use of a deadly weapon, a gun.”
New Mexico judge opens up separate BI limit for spouse’s consortium claim
A New Mexico Federal Magistrate Judge ruled on June 25 that a spouse’s loss of consortium claim alleged “bodily injury” separate from that sustained by her husband, who had been killed by USAA’s insured in an auto accident. As a result, the policy’s $200,000 per accident limit—rather than the $100,000 per person limit—was applicable to the claims....
Arizona Court of Appeals says auto medical payments benefits subject to health care provider lien
On April 5, Division One of the Arizona Court of Appeals decided an issue of first impression relating to whether an insurer’s medical payment benefits are subject to Arizona’s health care provider lien statute. They are. In summary, the Court stated, “The dispositive issue in this appeal is whether payments under optional medical payments coverage...
Gena Sluga receives ASU Barrett Honors College distinguished alumni award
Christian Dichter & Sluga shareholder Gena Sluga (left) was one of six honorees at the ASU Barrett Honors College Distinguished Alumni Awards event on April 4. Gena graduated from Barrett in 1994 before earning her law degree at the Boalt Hall School of Law at the University of California, Berkeley.
Nevada U.S. District Court: Waiver, not notice to insured, required for independent counsel
A Nevada federal district judge ruled on March 31 that notice to an insured of his right to independent counsel, where a conflict of interest existed between him and his insurer, did not satisfy the insurer’s contractual duty to defend. Rather, the insurer was required to obtain from the insured an express waiver of independent...
NV Supreme Court: Insurer’s breach of duty to defend exposes it to excess judgment even in absence of bad faith
The United States District Court for the District of Nevada certified the following question to the Nevada Supreme Court: ‘[w]hether, under Nevada law, the liability of an insurer that has breached its duty to defend, but has not acted in bad faith, is capped at the policy limit plus any costs incurred by the insured...
Arizona Court of Appeals sends big dram shop verdict back for new trial
Today, the Arizona Court of Appeals vacated a $7,903,494.58 Dram Shop judgment against JAI Dining Services and remanded it for a new trial because the trial judge failed to give an appropriate jury instruction on causation. The plaintiff was rear-ended by a drunk driver and badly injured. Plaintiff sued the driver and JAI where he...
Az Business Leaders: Gena Sluga included among top 5 insurance lawyers
Congratulations to CDS shareholder Gena Sluga on her inclusion in the 2019 AZ Business Leaders feature as one of the Top 5 Insurance Lawyers in AZ. Ms. Sluga is the only female lawyer recognized in the Insurance Law category. The feature is published annually by Arizona Business Magazine and the 2019 leaders were selected from...
CDS attorneys obtain summary judgment in lawsuit involving $1.5 million stipulated judgment
Christian, Dichter & Sluga attorney Gena Sluga obtained summary judgment in Arizona Federal District Court for an insurer facing a $1.5 million stipulated judgment in an insurance bad faith action. In Wilshire Insurance Company v. Yager , No. CV-16-00192-TUC-JAS, 2018 WL 5801537 (D. Ariz. Nov. 5, 2018), the auto insurer denied coverage for a car accident because, although the...
Ladder Down program featured in “2018 Women in Law”
The “2018 Women in Law” section of the October 2018 Phoenix edition of Attorney at Law magazine features a spotlight on the Ladder Down program co-founded by CDS attorneys. The Ladder Down program was founded in 2012 and ran for four years in Phoenix with support from the Arizona Association of Defense Counsel. The year-long program is...
Arizona Supreme Court nixes contractual liability exclusion; insurers to defend home buyer’s claim against seller
Yesterday, the Arizona Supreme Court issued a ruling clarifying the scope of the contractual liability exclusion in a homeowner’s policy. Teufel hired a contractor to build a home but ultimately decided not to live in it and sold it to Cetotor. After the sale, when rockslides damaged the property, Cetotor sued Teufel for breach of...
Arizona appeals court upholds post-loss assignment of property repair claims under HO policies
Homeowners hired a water restoration contractor to repair storm damage. The Work Order Agreement contained an assignment of the homeowners’ benefits and causes of action under any applicable insurance policy. Repair invoices were submitted to Homeowners’ insurer, Farmers, who paid what it determined to be the reasonable value of the services, but less than the...
Arizona Court of Appeals refines number-of-occurrences analysis
On May 31, Division 1 of the Arizona Court of Appeals rejected an insured’s argument that five independent acts of negligence causing a single accident entitled the insured to the aggregate claims limit of $2,000,000 rather that the $1,000,000 per occurrence limit of the CGL policy.
AZ Court of Appeals narrowly interprets limits of liability in motorcycle policy
Division One of the Arizona Court of Appeals decided on May 22nd that an insurer and its wholly owned subsidiary both provided underinsured motorist coverage to their insured under separate policies issued by each company. Hanfelder was injured in a motor vehicle accident. He collected the liability coverage limits from the responsible driver’s insurer and...
Partner J.P. Harrington Bisceglia Elected to AADC Board of Directors
Christian Dichter & Sluga is honored to announce that J.P. Harrington Bisceglia has been elected to the Board of Directors of the Arizona Association of Defense Counsel (AADC). The AADC is a non-profit organization established in April 1965 and is comprised of defense attorneys from all backgrounds who practice primarily in civil defense litigation. The AADC is...
CKDJS obtains Nevada Supreme Court win upholding exclusion in $1M umbrella policy
Filippo Sciarratta v. Foremost Insurance Company Grand Rapids Michigan, et al., No. 79604, 137 Nev. Adv. Op. 32 (Jul. 8, 2021). Summary. Christian, Kravitz, Dichter, Johnson & Sluga (“CKDJS”) recently secured a victory for their insurer clients before the Supreme Court of Nevada in an appeal regarding the validity of an exclusion for damages “payable to...
CDS shareholder Gena Sluga honored by Chambers USA
Christian Dichter & Sluga, P.C. is proud to announce that Chambers USA 2021 (a publication of Chambers of Partners) has once again recognized the firm in its annual rankings of the world’s leading law firms and lawyers. In the latest publication, the firm and shareholders Gena L. Sluga and Alison R. Christian were recognized in our core practice area...
Nevada Supreme Court: Insurer’s Right to Seek Reimbursement of Defense Costs
On March 11, 2021, the Supreme Court of Nevada issued an order answering a certified question posed by the United States Court of Appeals for the Ninth Circuit regarding the insurer’s right to seek reimbursement from the insured for defense costs associated with uncovered claims. Specifically, the question was: Is an insurer entitled to reimbursement...
Gena L. Sluga recognized in Top 100 Lawyers in Arizona for 2021!
CDS Shareholder Gena L. Sluga has been recognized in the Top Lawyers in Arizona for 2021! This prestigious group of lawyers is chosen by AZ Business Magazine’s editorial team in collaboration with industry experts. The attorneys are selected from a pool of more than 2,000 of the state’s most talented and successful attorneys. Selections are based on each...
CDS obtains Ninth Circuit win regarding coverage for a $1,500,000 Morris Agreement
Christian Dichter & Sluga recently secured victory for a client insurance company before the Ninth Circuit in an appeal over coverage for a $1,500,000 Morris Agreement. Appellant, as the assignee of a putative insured, alleged claims for breach of contract, waiver/estoppel and insurance bad faith arising from the insurer’s denial of adjustment of an automobile...
CDS shareholder Gena Sluga continues her active involvement with the Federation of Defense & Corporate Counsel for 2020-2021.
CDS shareholders Alison R. Christian and Gena L. Sluga continue their active involvement with the Federation of Defense & Corporate Counsel for 2020-2021. Ms. Christian has been appointed to serve as Vice-Chair of the Law Practice Management Section. She will also serve as Vice-Chair of various Committees, including the Insurance Industry Institute, Professional Women’s Forum,...
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702.362.6666
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