The California Court of Appeal reversed the trial court's grant of the insurer's demurrer on a COVID-19 claim and remanded the case for further proceedings. John's Grill v. Hartford Fin. Servs. Group, 2022 Cal. App. LEXIS 1056 (Cal. Ct. App. Dec. 27, 2022).

John's Grill had two insurers, Hartford and Sentinel. Hartford's motion to quash service of summons was granted by the trial court and affirmed by the appellate court. Sentinel's policy had customised trigger-of-coverage language that was virus-specific. The Sentinel endorsement (1) contained an affirmative grant of coverage specifically for "loss or damage" caused by a virus; and (2) a special definition of 'loss or damage" that included "direct physical loss or direct physical damage to" property, but was broad enough to encompass pervasive infiltration of virus particulates onto the surfaces of covered property, which is what John's Grill alleged here.