In Dana Incorporated v. Zurich American Insurance Company, Case No. 21-4150 (6th Cir. July 6, 2022), the Sixth Circuit recently addressed whether a “contamination exclusion” included within an insured’s property policy barred coverage for COVID-19 related losses. In Dana, Zurich issued an insurance policy to Dana Incorporated, a company that provided power-conveyance and energy-management solutions for vehicles and machinery. After suffering financial effects from the COVID-19 pandemic, including extra expenses and suspended operations, Dana sought coverage from Zurich under the policy. Zurich denied coverage and Dana sued. The district court dismissed Dana’s complaint, finding the policy’s “contamination exclusion” applied. The Sixth Circuit, on appeal, affirmed.