The Texas Supreme Court determined that language in the following form excess policy did not obligate it to defend the insured. Ohio Cas. Ins. Co. v Patterson UTI Energy, Inc., 2025 Tex. LEXIS 1123 (Tex. Sup. Ct. Dec. 20, 2024).

Patterson provided oil-and-gas equipment and services. Patterson was insured by a primary policy and multiple layers of excess coverage. For the 2017-2018 policy year, Patterson bought several lines of insurance through its broker, Marsh USA, Inc. The underlying policy was an umbrella policy issued by Liberty Mutual Insurance Europe, Ltd. Among the excess policies Patterson obtained through Marsh was one from Ohio Casualty Insurance Company.