An Arkansas appeals court has ruled that an insurer owes nothing to a contractor who was never added to its subcontractor’s policy.
The Arkansas Court of Appeals, in a decision delivered on March 11, 2026, affirmed summary judgment in favor of Auto-Owners Insurance Company in a coverage dispute that traces back to a residential remodel gone wrong in Little Rock. The case turns on a question insurance professionals encounter regularly: what happens when a general contractor assumes it has coverage under a subcontractor’s policy, but was never actually listed as an additional insured?
The story begins in 2010, when Chuck Hamilton Construction, a general residential building contractor, was hired by homeowners Kristen and Cliff Lee to remodel their house. Chuck Hamilton later brought on Freddie Cobbs, doing business as Cobbs Stonework, to handle stonework and masonry. Cobbs carried a commercial general-liability policy with Auto-Owners. Chuck Hamilton had its own separate CGL policy with Union Insurance Company…