The judges of the Seventh Circuit found the additional insured on a CGL policy was only entitled to coverage up until the date the underlying suit was settled. The case is United Fire & Cas. Co. v. Prate Roofing & Installations, LLC, 7 F.4th 573 (7th Cir. 2021). 

A roofing company based in Tennessee, All Seasons Roofing, Inc., was hired to inspect the roofs on two warehouses in Illinois. All Seasons found hail damage but could not repair the roof itself because it was not licensed in Illinois. All Seasons then entered a contract with Prate Roofing & Installations, LLC, an Illinois-licensed company, to serve as the general contractor for the repairs with All Seasons working as a subcontractor. In accordance with that contract, All Seasons purchased a CGL policy from United Fire & Casualty Company and named Prate as an additional insured. 

One day, an employee from a third, non-party company died after falling through an unprotected skylight at one of the warehouses. Though his estate's remedies against his direct employer were limited to workers compensation, the estate was able to pursue wrongful death claims against Prate, All Seasons, the company that owned the warehouses, and the company that managed the warehouses. The estate's complaint alleged that "Prate … by and through its agents, servants and employees, was then and there guilty of one or more of the following careless and negligent acts and/or omissions…." (emphasis added).