The court denied cross motions for summary judgment after analyzing the application of a total pollution exclusion. Nat’l Am. Ins. Co. v. Certain Underwriters at Lloyd’s London, 2026 U.S. Dist. LEXIS 98232 (W.D. Texas March 16, 2026).

Skye Blue Services, LLC and Blackbeard entered into a Master Service Agreement (MSA) governing Skye’s provision of oilfield services to Blackbeard. The MSA required Skye to name Blackbeard as an additional insured on Skye’s policies and to indemnify Blackbeard for bodily injury claims brought by Skye employees.

Two Skye employees were injured when working at Blackbeard’s Marooner tank battery facility. They were cleaning the inside of a heater treater tank when an explosion or flash fire occurred inside the heater treater, injuring the two employees.