Forecast Homes, Inc. v. Steadfast Insurance Co.


Forecast is a housing developer. It required its subcontractors to obtain policies of insurance that included Additional Insured Endorsements naming Forecast as an additional insured under the policy. Forecast did not require any specific language regarding the insurances policies’ self-insured retention (SIR) provisions.

Several subcontractors obtained the required insurance coverage from Steadfast. Steadfast denied Forecast’s tender of defense on the ground that the subcontractor had not paid the policy’s SIR. Steadfast argued that, under the terms of the policy, only the named insured (not Forecast) could satisfy the SIR and trigger coverage.

Forecast filed a declaratory relief action against Steadfast. The trial court ruled in favor Steadfast. Forecast appeals.


Affirmed. The language of the insurance policy controls. Here, the policy endorsements regarding SIRs specifically defined and identified the named insured (not an additional insured) as the entity required to satisfy the SIR as a precondition to coverage. Who may satisfy an SIR depends on a policy’s express terms.