Because the phrase “short time” is undefined and does not fix a precise upper boundary for the length of time that an employee may be away from the coverage territory, we look to the dictionary definition of “short” for help.  The ordinary meaning of the adjective “short” is well established; it means “lasting a brief time.”

A handful of courts have examined the meaning of the phrase “a short time” and found that it must be read in the context of the entire policy. In July 2008, a Virginia district court found that it would “strain the ordinary meaning of 'a short time' away from the coverage territory to include a multi-month overseas deployment in the context of a policy twelve months in duration.”  (See 2008 WL 2890881)

The court explained that it was clear that this provision “extends coverage only to brief business trips where the employee's permanent work site or duty station remains inside the coverage territory.”

Courts have also stated that because the phrase “short time” is undefined and does not fix a precise upper boundary for the length of time that an employee may be away from the coverage territory, the ordinary dictionary meaning should be used as guidance.

Because it is ultimately up to the individual insurer to decide whether the month spent by the contractor in Mexico exceeds the time limit contemplated by the drafters of the CGL policy, and it may vary with jurisdiction, there is no ironclad, one-size-fits-all answer to the question.