Physical Alteration of Insured Property is not Required for Coverage Under a Communicable Disease Coverage Extension Where “Direct Physical Loss or Damage” Under the Terms of the Insurance Policy Includes Costs Incurred by an Insured to Disinfect, Mitigate or Monitor the Effects of a Communicable Disease at an Insured Property

In Amy’s Kitchen, Inc. v. Fireman’s Fund Insurance Company (No. A163767), filed October 4, 2022, the Court of Appeal of the State of California, First Appellate District held physical alteration of insured property was not required for coverage under a communicable disease coverage extension or a loss avoidance or mitigation coverage extension where “direct physical loss or damage” under the terms of the property insurance policy includes necessary costs incurred by an insured to disinfect, mitigate or monitor the effects of a communicable disease.