A Texas appellate court reversed a trial court verdict that found physical particles of Covid-19 caused physical damage covered by a CGL policy. The case is Lloyd's Syndicate 1967 Subscribing to Pol'y B0180PG1922227 v. Baylor Coll. of Med., 2025 Tex. App. LEXIS 378 (Tex. Ct. App. 2025).

The onset of the Covid-19 pandemic (the Pandemic) forced the partial or complete closure of schools and businesses across the country. The Baylor College of Medicine (Baylor) could not fully shut down because the healthcare professionals at Baylor still had to see patients. A myriad of safety measures, such as stringent cleaning and disinfecting protocols, were implemented to mitigate the risk of transmitting Covid-19.

Later, as social distancing and occupancy restrictions were being lifted, Baylor submitted a claim to Lloyd’s Syndicate 1967 (Lloyd’s). The insurer declined the claim for a lack of physical damage, which prompted Baylor to file suit against Lloyd’s.