The District Court for the District of South Carolina ruled that a coverage extension for "civil authority" did not cover a business interruption loss due to a governor's evacuation order ahead of a hurricane. The case is Kelaher, Connell & Conner, P.C. v. Auto-Owners Ins. Co., 440 F. Supp. 3d 520 (D.S.C. 2020). 

Kelaher, Connell & Conner (Kelaher) is a law firm located near the eastern coast of South Carolina. As Hurricane Florence was approaching in September 2018, the governor of South Carolina issued an executive order mandating evacuation for areas on the South Carolina coast, including the area where the Kelaher offices were located. The governor's order was lifted, and Kelaher returned to the offices, 3.5 days later. 

Kelaher had purchased a businessowners policy from Auto-Owners that included an extension for "civil authority" coverage. This extension would apply to business interruption losses incurred by Kelaher when "access to the described business premises is prohibited by order of civil authority because of damage or destruction of property adjacent to the described premises by the perils insured against" precipitated the loss. Kelaher submitted a claim to Auto-Owners for the time lost due to the governor's evacuation order. Auto-Owners denied the claim, and Kelaher filed suit.