Robinson Cole LLP
High Contrast Mode
Marquee

Insurance + Reinsurance

Our Insurance + Reinsurance practice group represents insurance companies and reinsurers in a wide spectrum of matters. We are a team of experienced insurance lawyers, and leaders in our fields.

Our Services

Our Insurance + Reinsurance lawyers have broad experience in complex coverage and claims litigation involving:

  • Disability
  • Directors and officers
  • Excess
  • Health
  • Liability
  • Life
  • Marine and inland marine
  • Professional liability
  • Property
  • Reinsurance
  • Title policies
  • Uninsured + underinsured motorist

Our team also handles subrogation, class action and extracontractual claims litigation. We represent insurers in administrative matters involving state insurance and tax departments, investment and real estate transactions, agency relationships, compliance, and employment matters.

Our Team

Through our collaborative approach, our Insurance + Reinsurance team benefits from Robinson+Cole’s broad substantive abilities in defending environmental liability, products liability, title and real estate defects, professional liability, and construction defect claims made against policyholders by third parties.

Based in the Northeast, our expanding practice covers matters across the United States. Many of our lawyers hold leadership roles in national and international professional organizations related to insurance law, including:

  • Professionals', Officers' and Directors' Liability Committee of the Tort Trial and Insurance Practice Section (TIPS) of the American Bar Association (ABA)
  • Property Insurance Law Committee of the ABA
  • Federation of Defense & Corporate Counsel (FDCC)
  • Property Insurance Committee of the International Association of Defense Counsel (IADC)
  • Loss Executives Association (LEA)

Our attorneys are also regular panelists at meetings of the Property Loss Research Bureau (PLRB), the Defense Research Institute (DRI), and other educational programs. Two of our members developed and teach a course in property insurance law, offered as part of the Master of Laws program through the Insurance Law Center at the University of Connecticut School of Law.

Our Insurance + Reinsurance practice group provides legal services for insurers navigating administrative matters, and all types of complex coverage issues and claims litigation.

Experience

Commercial Property: Water Damage to Computers + Electronics

Lead trial counsel for insurer in a multi-week arbitration involving a $20 million commercial property insurance claim for water damage to computer chips and other electronic equipment. The arbitration included the expert testimony of computer scientists on the technical specifications of the computer chips and electronic equipment, consultants on the valuation of the insured’s vast inventory, and forensic accountants on the alleged business income loss.

Read More

Commercial General Liability: Late Notice of Claims

Won dismissal of federal court litigation addressing multi-million-dollar coverage dispute under a commercial general liability policy arising from judgment entered after trial. Summary judgment granted based on late notice defense raising novel legal issues.

Read More

Directors + Officers Liability: Prior Related Claims

Lead counsel in arbitration arising from multi-million-dollar settlement of claims against former directors and officers of a publicly traded company. The matter involved disputed coverage under a multi-insurer D&O tower, with allegations centering on the applicability of related claims provisions and specific matter exclusions.

Read More

Publications

December 4, 2025

11th Circ.’s 6-Step Review May Be Ripe for Insurer Challenge

Law360 Expert Analysis

By a 2-1 vote in Johnson v. Reliance Standard Life Insurance Co., the U.S. Court of Appeals for the Eleventh Circuit has held that a policy interpretation endorsed by the dissenting opinion, suggested by a prior Eleventh Circuit panel, and adopted by other courts around the country was not just wrong, but so unreasonable that it failed arbitrary-and-capricious review. The Nov. 21 decision is a cautionary tale in several respects.[1] The dispute arose under a long-term disability, or LTD, policy that excluded coverage for preexisting conditions, defined as "any Sickness or Injury for which the Insured received medical Treatment, consultation, care or services, including diagnostic procedures, or took prescribed drugs or medicines." For two years prepolicy, the plaintiff had symptoms of a rare autoimmune disease, scleroderma. She received treatment, took medicines, and underwent diagnostic procedures. But none of her doctors could figure out what it was, diagnosing her with nearly a dozen other ailments instead. After the policy kicked in, her doctors landed on the correct diagnosis. The question for the court was whether something counts as a preexisting condition if the insured was treated for it prepolicy, but her doctors didn't name it correctly. The Result The majority answered no, holding that the insurer thus wrongly denied coverage. This outcome was unlikely for two main reasons. First, this was an LTD policy under the Employee Retirement Income Security Act that granted the insurer "discretionary authority" to interpret it. The insurer could lose only if its interpretation was not just wrong, but so unreasonable as to be "arbitrary and capricious." Second, multiple judges already had interpreted similar policy language in line with the insurer's interpretation. The deferential standard of review may have been diluted in part due to a quirk of the Eleventh Circuit. In contrast to other circuits that apply regular abuse-of-discretion review to an insurer's discretionary interpretation of its own ERISA policy, the Eleventh Circuit uses a bespoke six-step sequence that starts by asking whether the insurer's interpretation is wrong under de novo review, then only later asks if it is so wrong as to be arbitrary and capricious. This sequence triggers what influence scholar and renowned psychologist Robert Cialdini calls "commitment-and-consistency bias": Someone is more likely to agree with a stance if they first agree with it a little. Here, once a judge convinces themself that an interpretation is wrong, there is a stronger cognitive temptation to believe it is also very wrong. By contrast, leading with the abuse-of-discretion question creates a more level playing field. Second, at the policy interpretation stage, things got metaphysical. The majority viewed the Scott Garosshen prepolicy doctors' activities as treating symptoms rather than a medical condition. Because they repeatedly misdiagnosed the plaintiff with other ailments instead of scleroderma, the majority reasoned, they could not have been treating her "for" scleroderma. The "symptoms are not the disease" and "an indication of something is not the thing itself," just as "a wet umbrella is [not] 'the same thing' as a hurricane." The dissent saw it differently. The plaintiff had been treated, prescribed medication, and undergone diagnostics "for the 'various symptoms and conditions of scleroderma.'" There was "more than mere 'consistency' between what [she] was treated for and scleroderma; they are the same thing." Borrowing an umbrella of its own, the dissent reasoned that if one "us[es] an umbrella to stay dry without knowing whether the current rainstorm is a hurricane or quick summer shower," either way, "the umbrella fends off the rains." Since both majority and dissent found different dictionaries and prior cases siding with their respective interpretations, one would expect the insurer to prevail under arbitrary-andcapricious review. Instead, the majority seized on a stray answer at oral argument, construing it as an admission that the insurer would deny coverage if any prepolicy symptom was not inconsistent with the later diagnosis. The majority held that that position, albeit taken from another party in a different case, "is unreasonable — full stop." So, it reversed the judgment of the U.S. District Court for the Northern District of Georgia. Looking Ahead This appeal seems ripe for rehearing en banc; although, this is quite rare, especially in insurance coverage cases. As to standard of review, even the majority acknowledged that the Eleventh Circuit's six-step sequence "is likely unnecessarily complex (and may even obscure the lawful result in certain cases)" — the result here is a prime example. If not now, then when the right case comes along, insurers may consider investing in overturning this framework and the subtle cognitive bias it creates. Doing so will aid not just litigants, but also the court. That six-step structure does not only obscure the correct result; it is also unwieldy to apply. The majority nodded to this when it suggested in passing that the contra proferentem rule, requiring a court to defer to the policyholder's reasonable interpretation of ambiguous language, might bolster its conclusion at interpretive step one — i.e., whether, under de novo review, the insurer's interpretation was wrong. Critically, that rule goes out the window at step three — during abuse-of-discretion review, a court must defer to the insurer's reasonable interpretation of ambiguous language. So, the court winds up disregarding its earlier work. Other circuits hold overwhelmingly that contra proferentem simply plays no role in abuseof-discretion review.[2] Only the U.S. Court of Appeals for the Fifth Circuit, in its 2019 decision in Dialysis Newco Inc. v. Community Health Systems Group Health Plan, has come out differently in the limited context of interpreting anti-assignment clauses, while acknowledging that this outlier holding created "some tension in [its] caselaw" and may be due for correction.[3] It is thus no wonder that the Eleventh Circuit majority here, after invoking contra proferentem, disavowed any reliance on it, even in step one. That awkward dance (and the makework it entails) could be avoided if the Eleventh Circuit jettisons the six-step framework and joins the rest of the country in assessing simply whether the insurer has discretion, and, if so, whether its interpretation passes abuse-of-discretion review. Turning to the Eleventh Circuit majority's merits policy interpretation, how lower courts apply that test will be key. The test seems to be that the right disease need not be formally diagnosed prepolicy so long as it at least is "suspected." The majority suggests that "strong indications" of the particular illness, "reasonable cause" to diagnose the particular illness, or "a distinct symptom or condition from which one learned in medicine can diagnose the disease" all trigger the preexisting conditions exclusion but were not satisfied on the facts here. Whether that blurry line will yield consistent results in practice remains to be seen. Key Takeaways for Insurers 1. Look out for interpretive frameworks that create commitment-and-consistency bias. Experiments have shown that judges are susceptible to this type of cognitive effect. Although hard to prove in any given case, the long-term effect can be significant. Investing in reshaping the law into a more level playing field affects not just the individual cases but also their broader ripples into adjacent case law. 2. Pay special attention to outlier circuits. When a circuit decision flags one of its own rules as out-of-step with the modern trend, it may be vulnerable to reconsideration en banc, without the need for a trip all the way to One First Street, Washington, D.C. This is especially true when experience has shown the rule to be unworkable. 3. Issue framing and careful answers at oral argument matter. Insurers are often held to a higher standard, even when the law requires more lenient treatment. The effect of this can be mitigated by having a firm theory of the case and knowing exactly when one can, cannot, or must cede ground. [1] Johnson v. Reliance Standard Life Insurance Company, No. 23-13443, 2025 WL 3251015 (11th Cir. Nov. 21, 2025). [2] Dialysis Newco Inc. v. Cmty. Health Sys. Grp. Health Plan, 938 F.3d 246, 251 n.4 (5th Cir. 2019) (noting decisions from the First, Second, Fourth, Sixth, Seventh, Ninth, Tenth and Eleventh Circuits). [3] Dialysis Newco, 938 F.3d at 251.

November 25, 2025

1st Circ. Offers Diversity Jurisdiction Lessons For Assignees

Law360 Expert Analysis

Practitioners know that in order to bring a diversity action in federal court, the amount in dispute must exceed the statutory minimum and there must be complete diversity of citizenship between the plaintiffs and defendants. Assignments can complicate this analysis because Title 28 of the U.S. Code, Section 1359, provides in relevant part that "[a] district court shall not have jurisdiction of a civil action in which any party, by assignment or otherwise, has been improperly or collusively made ... to invoke the jurisdiction of such court." An Oct. 16 opinion from the U.S. Court of Appeals for the First Circuit in Gore and Associates Management Co. v. SLSCO Ltd. serves as a cautionary tale about what can go wrong — dismissal after years of litigation — if an assignee invoking the jurisdiction of the federal courts has not alleged sufficient facts, or created a sufficient record, to demonstrate there is complete diversity between not only the parties to the action, but also between the putative assignors and parties on the counterparties to the assignee.[1] Background On July 6, 2019, the plaintiff Gore and Associates filed a diversity action in the U.S. District Court for the District of Puerto Rico against the defendant SLSCO and its surety, Hartford Fire Insurance Co., for alleged breach of contract, failure to pay a third-party bond claim, and a payment bond claim under the Puerto Rican Little Miller Act.[2] Specifically, Gore alleged that SLSCO failed to pay invoices submitted by Gore's nonparty subcontractors — Earthwrx LLC, Uniify of Puerto Rico LLC and Uniify Strategic Business Solutions LLC — under several federal contracts related to rebuilding projects in Puerto Rico and the U.S. Virgin Islands after 2017's Hurricane Maria. In the complaint, Gore alleged that its subcontractors assigned their respective rights under the aforementioned invoices to Gore. Preappeal Trial Court Proceedings The defendants moved to dismiss on the ground that the plaintiff's action violated a valid contractual forum selection clause, for failure to state a claim under Rule 12(b)(6) of the Federal Rules of Civil Procedure, and, in the alternative, sought a stay of any surviving claims pending completion of contractually mandated mediation proceedings, but did not challenge the court's subject matter jurisdiction pursuant to Rule 12(b)(1). The trial court dismissed without prejudice certain subcontract-related claims, but refused to dismiss claims under two specific bonds and the Little Miller Act. The district court thereafter instructed Gore to file the dismissed claims in the appropriate forums and return to this case once those claims had been disposed. The case was then stayed. Gore sought reconsideration, leave to amend their complaint and to lift the stay, but the district court denied the requested relief and an appeal followed. Diversity Issue Arises On appeal, the First Circuit sua sponte noted that the while the complaint alleged that Gore was assigned rights by Earthwrx and the Uniify entities, the record did not provide sufficient information to determine whether there was subject matter jurisdiction. As such, the First Circuit ordered the parties to provide supplemental submissions and specifically ordered Gore to provide information about the citizenship of each alleged assignor. The parties complied with the First Circuit's order to file supplemental submissions. Gore posited that the court had adequate diversity jurisdiction. In so contending, it represented that, upon information and belief, Earthwrx was wholly owned by 541 LLC, an Oregon limited liability company with a principal place of business in Oregon. Gore also represented, again upon information and belief, that Uniify of Puerto Rico, a Puerto Rican entity, was wholly owned by Uniify Strategic Business Solutions LLC, a Louisiana company. However, Gore did not submit any evidence to support its position. Unsatisfied, the First Circuit remanded the case for jurisdictional fact-finding, specifically directing the district court to determine: (1) whether each individual subcontractor was completely diverse from the defendants and, if not; (2) whether the assignments to Gore were a collusive attempt to manufacture diversity jurisdiction in violation of Section 1359. Remand Proceedings On remand, the parties agreed to exchange written discovery and reserved the right to take depositions, but no party requested an evidentiary hearing and, instead, they opted to submit simultaneous briefs with accompanying evidence on the jurisdictional issues. In support of the contention that diversity jurisdiction exists for Earthwrx, Gore submitted a certificate of formation, allowing the district court to find that Earthwrx was a Puerto Rican company and James A. Young and Bobby Owens were listed as authorized persons, administrators and members of the LLC. The court determined that none of this information was helpful in assessing whether there was complete diversity between Earthwrx and the defendants. More problematic was that this evidence contradicted Gore's prior submission to the First Circuit that suggested Earthwrx was solely owned by 541 LLC. No documentation was provided to the district court regarding 541 LLC. While Gore did submit some additional public documentation obtained regarding property purchased by Earthwrx's members, it was plainly hearsay and unauthenticated. An email chain was also submitted, but there was no context for the statements therein, even though, according to Gore, its purported purpose was to show that the assignments were to consolidate claims, avoid unnecessary litigation costs and avoid inconsistent judgments. As for the Uniify entities, the court was only able to determine that Uniify was created on Nov. 18, 2017; that Terry Bee was listed as the president, administrator and authorized person for the LLC; and that Uniify Strategic was determined to be an inactive Louisiana LLC that included Bee and Joseph P. Meyer as officers. These findings once again conflicted with Gore's prior position before the First Circuit as it had previously reported that Uniify of Puerto Rico was wholly owned by Uniify Strategic, which, according to the district court, militated against Gore's position. As it had regarding Earthwrx, Gore submitted several additional documents that also ran afoul of the Federal Rules of Evidence in that they were inadmissible hearsay, unauthenticated, unreliable, speculative, inconsistent and simply not helpful to assessing diversity as of the date the action was filed. Outcome Given the foregoing, the U.S. District Court for the District of Puerto Rico was unable to accomplish the First Circuit's remand directive and could not analyze whether there was complete diversity between any of the alleged assignors-subcontractors and defendants — much less turn to the second question of examining the motive behind a particular assignment if there was not complete diversity between any particular assignor-subcontractor and the defendants. The First Circuit held that this was fatal to Gore's suit because it bore the burden of demonstrating the validity of the assignments, as the party seeking to invoke diversity jurisdiction. While Gore sought another remand to conduct additional discovery and seek an evidentiary hearing, the First Circuit refused to do so because Gore had already been given two opportunities to provide evidence of diversity and allowed seven months for the exact purpose of conducting discovery and seeking an evidentiary hearing. The case was dismissed. Key Lessons for Assignees Seeking to Invoke Diversity Jurisdiction If an assignee plans to invoke the diversity jurisdiction of a federal court, it cannot rely solely on the diversity of the parties to the action (if first filed in state court) or eventual action. Instead, the assignee ought to conduct a rigorous investigation into the citizenship of each and every assignor whose rights the assignee is asserting prior to bringing an action. Furthermore, assuming an assignor is an LLC, it is incumbent on the assignee to investigate the citizenship of all members of such entity.[3] If the members of a particular LLC are themselves unincorporated associations, then a deeper, iterative investigation is required; the citizenship of any member must be traced through "however many layers of members or partners there may be," according to the First Circuit's 2023 decision in BRT Management LLC v. Malden Storage LLC.[4] Assuming there is complete diversity of citizenship between the assignors and defendants, the assignee can — and should — allege that to guard against a court sua sponte raising an issue with subject matter jurisdiction midsuit or, worse, after years of litigation. Better yet, an assignee ought to have evidence at its disposal to establish the citizenship of each assignor at the time the action is filed, which is the only date that matters because diversity jurisdiction is determined as of that date.[5] A subsequent change in domicile for an assignor (or any party for that matter) will not defeat existence of diversity.[6] But an assignee should not have just any evidence — it should have evidence that would be admissible under the Federal Rules of Evidence to avoid authentication, hearsay or other admissibility problems. Additionally, an assignee should be able to explain how each piece of evidence supports the diversity analysis. Failure to do so may lead to a court determining it has not been provided with sufficient evidence, which may very well be fatal if the assignee is the one attempting to invoke the diversity jurisdiction as it would bear the burden of establishing subject matter jurisdiction once raised.[7] Should an opponent of assignment raise a Section 1359 challenge to the court's diversity jurisdiction, or if the court questions its subject matter jurisdiction, and the assignee is in the awkward position of not having sufficient information or evidence to make its showing, it ought to request sufficient time to conduct a rigorous investigation into the issues such that it is not in the position of having to rely on representations made on information and belief in the first instance and then later providing contradictory information or, worse yet, evidence. Doing so will not help the assignee's credibility and could raise the specter of sanctions under Rule 11 of the Federal Rules of Civil Procedure. Key Lessons for Nonassignee Opponents Conversely, a nonassignee should investigate any assignment-related allegations or disclosures thoroughly. If the non-assignee has a good faith basis to suspect that diversity jurisdiction exists only as the result of an assignment, then it should alert the federal court to the potential jurisdictional defect. This will force the assignee to provide the court with sufficient, admissible evidence that there was complete diversity at the commencement of the action and avoid an issue raised years later on appeal. If the assignee fails to do so, then the nonassignee ought to detail the deficiencies in the assignee's evidence and explain to the court how the assignee's burden has not been met. A Note on the Presumption of an Invalid Assignment If the district court on remand was unable to analyze whether there was complete diversity between any of Gore's assignor-subcontractors and the defendant (SLSCO) and its surety (Hartford Fire Insurance), that would have been the end of the analysis. However, if the district court determined that there was incomplete diversity between defendants and a particular assignor-subcontractor, then that assignment would have been presumptively ineffective for purposes of Section 1359.[8] While rebutting this presumption is "likely to be difficult," it is incumbent on the assignee-party to prove that it was not made collusively by way of a "credible showing of a legitimate reason for the transfer" that was "unrelated to the fabrication of federal court jurisdiction," according to the U.S. Court of Appeals for the Eighth Circuit's 2004 opinion in McCulloch v. Velez.[9] Given that credibility is in play to rebut this collusion presumption, live testimony likely will be advisable, if not absolutely necessary. Indeed, had the district court turned to the second question on remand, it telegraphed its displeasure with the documentary submission of an email that provided no context for the statements therein despite said email purporting to be evidence of a valid purpose for the assignments. Gore and Assocs. Mgmt. Co. v. SLSCO Ltd., --- F.4th ---, 2025 WL 2938795 (1st Cir. 2025). P.R. Laws Ann. Tit. 22, § 51. BRT Mgmt. LLC v. Malden Storage LLC, 68 F.4th 691, 696 (1st Cir. 2023) (internal quotation marks omitted). Id. Bank One, Texas, N.A. v. Montle, 964 F.2d 48, 49 (1st Cir. 1992). Id. E.g., Woo v. Spackman, 988 F.3d 47, 53 (1st Cir. 2021) (party who asserts jurisdiction bears burden of establishing that it exists by a preponderance of the evidence). McCulloch v. Velez, 364 F.3d 1, 6 (8th Cir. 2004). Id.

COVID-19 Business Interruption Cases Reach the End of the Road, with Mixed Results teaser
September 2, 2025

COVID-19 Business Interruption Cases Reach the End of the Road, with Mixed Results

Covering Appeals
December 4, 2025

11th Circ.’s 6-Step Review May Be Ripe for Insurer Challenge

Law360 Expert Analysis

By a 2-1 vote in Johnson v. Reliance Standard Life Insurance Co., the U.S. Court of Appeals for the Eleventh Circuit has held that a policy interpretation endorsed by the dissenting opinion, suggested by a prior Eleventh Circuit panel, and adopted by other courts around the country was not just wrong, but so unreasonable that it failed arbitrary-and-capricious review. The Nov. 21 decision is a cautionary tale in several respects.[1] The dispute arose under a long-term disability, or LTD, policy that excluded coverage for preexisting conditions, defined as "any Sickness or Injury for which the Insured received medical Treatment, consultation, care or services, including diagnostic procedures, or took prescribed drugs or medicines." For two years prepolicy, the plaintiff had symptoms of a rare autoimmune disease, scleroderma. She received treatment, took medicines, and underwent diagnostic procedures. But none of her doctors could figure out what it was, diagnosing her with nearly a dozen other ailments instead. After the policy kicked in, her doctors landed on the correct diagnosis. The question for the court was whether something counts as a preexisting condition if the insured was treated for it prepolicy, but her doctors didn't name it correctly. The Result The majority answered no, holding that the insurer thus wrongly denied coverage. This outcome was unlikely for two main reasons. First, this was an LTD policy under the Employee Retirement Income Security Act that granted the insurer "discretionary authority" to interpret it. The insurer could lose only if its interpretation was not just wrong, but so unreasonable as to be "arbitrary and capricious." Second, multiple judges already had interpreted similar policy language in line with the insurer's interpretation. The deferential standard of review may have been diluted in part due to a quirk of the Eleventh Circuit. In contrast to other circuits that apply regular abuse-of-discretion review to an insurer's discretionary interpretation of its own ERISA policy, the Eleventh Circuit uses a bespoke six-step sequence that starts by asking whether the insurer's interpretation is wrong under de novo review, then only later asks if it is so wrong as to be arbitrary and capricious. This sequence triggers what influence scholar and renowned psychologist Robert Cialdini calls "commitment-and-consistency bias": Someone is more likely to agree with a stance if they first agree with it a little. Here, once a judge convinces themself that an interpretation is wrong, there is a stronger cognitive temptation to believe it is also very wrong. By contrast, leading with the abuse-of-discretion question creates a more level playing field. Second, at the policy interpretation stage, things got metaphysical. The majority viewed the Scott Garosshen prepolicy doctors' activities as treating symptoms rather than a medical condition. Because they repeatedly misdiagnosed the plaintiff with other ailments instead of scleroderma, the majority reasoned, they could not have been treating her "for" scleroderma. The "symptoms are not the disease" and "an indication of something is not the thing itself," just as "a wet umbrella is [not] 'the same thing' as a hurricane." The dissent saw it differently. The plaintiff had been treated, prescribed medication, and undergone diagnostics "for the 'various symptoms and conditions of scleroderma.'" There was "more than mere 'consistency' between what [she] was treated for and scleroderma; they are the same thing." Borrowing an umbrella of its own, the dissent reasoned that if one "us[es] an umbrella to stay dry without knowing whether the current rainstorm is a hurricane or quick summer shower," either way, "the umbrella fends off the rains." Since both majority and dissent found different dictionaries and prior cases siding with their respective interpretations, one would expect the insurer to prevail under arbitrary-andcapricious review. Instead, the majority seized on a stray answer at oral argument, construing it as an admission that the insurer would deny coverage if any prepolicy symptom was not inconsistent with the later diagnosis. The majority held that that position, albeit taken from another party in a different case, "is unreasonable — full stop." So, it reversed the judgment of the U.S. District Court for the Northern District of Georgia. Looking Ahead This appeal seems ripe for rehearing en banc; although, this is quite rare, especially in insurance coverage cases. As to standard of review, even the majority acknowledged that the Eleventh Circuit's six-step sequence "is likely unnecessarily complex (and may even obscure the lawful result in certain cases)" — the result here is a prime example. If not now, then when the right case comes along, insurers may consider investing in overturning this framework and the subtle cognitive bias it creates. Doing so will aid not just litigants, but also the court. That six-step structure does not only obscure the correct result; it is also unwieldy to apply. The majority nodded to this when it suggested in passing that the contra proferentem rule, requiring a court to defer to the policyholder's reasonable interpretation of ambiguous language, might bolster its conclusion at interpretive step one — i.e., whether, under de novo review, the insurer's interpretation was wrong. Critically, that rule goes out the window at step three — during abuse-of-discretion review, a court must defer to the insurer's reasonable interpretation of ambiguous language. So, the court winds up disregarding its earlier work. Other circuits hold overwhelmingly that contra proferentem simply plays no role in abuseof-discretion review.[2] Only the U.S. Court of Appeals for the Fifth Circuit, in its 2019 decision in Dialysis Newco Inc. v. Community Health Systems Group Health Plan, has come out differently in the limited context of interpreting anti-assignment clauses, while acknowledging that this outlier holding created "some tension in [its] caselaw" and may be due for correction.[3] It is thus no wonder that the Eleventh Circuit majority here, after invoking contra proferentem, disavowed any reliance on it, even in step one. That awkward dance (and the makework it entails) could be avoided if the Eleventh Circuit jettisons the six-step framework and joins the rest of the country in assessing simply whether the insurer has discretion, and, if so, whether its interpretation passes abuse-of-discretion review. Turning to the Eleventh Circuit majority's merits policy interpretation, how lower courts apply that test will be key. The test seems to be that the right disease need not be formally diagnosed prepolicy so long as it at least is "suspected." The majority suggests that "strong indications" of the particular illness, "reasonable cause" to diagnose the particular illness, or "a distinct symptom or condition from which one learned in medicine can diagnose the disease" all trigger the preexisting conditions exclusion but were not satisfied on the facts here. Whether that blurry line will yield consistent results in practice remains to be seen. Key Takeaways for Insurers 1. Look out for interpretive frameworks that create commitment-and-consistency bias. Experiments have shown that judges are susceptible to this type of cognitive effect. Although hard to prove in any given case, the long-term effect can be significant. Investing in reshaping the law into a more level playing field affects not just the individual cases but also their broader ripples into adjacent case law. 2. Pay special attention to outlier circuits. When a circuit decision flags one of its own rules as out-of-step with the modern trend, it may be vulnerable to reconsideration en banc, without the need for a trip all the way to One First Street, Washington, D.C. This is especially true when experience has shown the rule to be unworkable. 3. Issue framing and careful answers at oral argument matter. Insurers are often held to a higher standard, even when the law requires more lenient treatment. The effect of this can be mitigated by having a firm theory of the case and knowing exactly when one can, cannot, or must cede ground. [1] Johnson v. Reliance Standard Life Insurance Company, No. 23-13443, 2025 WL 3251015 (11th Cir. Nov. 21, 2025). [2] Dialysis Newco Inc. v. Cmty. Health Sys. Grp. Health Plan, 938 F.3d 246, 251 n.4 (5th Cir. 2019) (noting decisions from the First, Second, Fourth, Sixth, Seventh, Ninth, Tenth and Eleventh Circuits). [3] Dialysis Newco, 938 F.3d at 251.

November 25, 2025

1st Circ. Offers Diversity Jurisdiction Lessons For Assignees

Law360 Expert Analysis

Practitioners know that in order to bring a diversity action in federal court, the amount in dispute must exceed the statutory minimum and there must be complete diversity of citizenship between the plaintiffs and defendants. Assignments can complicate this analysis because Title 28 of the U.S. Code, Section 1359, provides in relevant part that "[a] district court shall not have jurisdiction of a civil action in which any party, by assignment or otherwise, has been improperly or collusively made ... to invoke the jurisdiction of such court." An Oct. 16 opinion from the U.S. Court of Appeals for the First Circuit in Gore and Associates Management Co. v. SLSCO Ltd. serves as a cautionary tale about what can go wrong — dismissal after years of litigation — if an assignee invoking the jurisdiction of the federal courts has not alleged sufficient facts, or created a sufficient record, to demonstrate there is complete diversity between not only the parties to the action, but also between the putative assignors and parties on the counterparties to the assignee.[1] Background On July 6, 2019, the plaintiff Gore and Associates filed a diversity action in the U.S. District Court for the District of Puerto Rico against the defendant SLSCO and its surety, Hartford Fire Insurance Co., for alleged breach of contract, failure to pay a third-party bond claim, and a payment bond claim under the Puerto Rican Little Miller Act.[2] Specifically, Gore alleged that SLSCO failed to pay invoices submitted by Gore's nonparty subcontractors — Earthwrx LLC, Uniify of Puerto Rico LLC and Uniify Strategic Business Solutions LLC — under several federal contracts related to rebuilding projects in Puerto Rico and the U.S. Virgin Islands after 2017's Hurricane Maria. In the complaint, Gore alleged that its subcontractors assigned their respective rights under the aforementioned invoices to Gore. Preappeal Trial Court Proceedings The defendants moved to dismiss on the ground that the plaintiff's action violated a valid contractual forum selection clause, for failure to state a claim under Rule 12(b)(6) of the Federal Rules of Civil Procedure, and, in the alternative, sought a stay of any surviving claims pending completion of contractually mandated mediation proceedings, but did not challenge the court's subject matter jurisdiction pursuant to Rule 12(b)(1). The trial court dismissed without prejudice certain subcontract-related claims, but refused to dismiss claims under two specific bonds and the Little Miller Act. The district court thereafter instructed Gore to file the dismissed claims in the appropriate forums and return to this case once those claims had been disposed. The case was then stayed. Gore sought reconsideration, leave to amend their complaint and to lift the stay, but the district court denied the requested relief and an appeal followed. Diversity Issue Arises On appeal, the First Circuit sua sponte noted that the while the complaint alleged that Gore was assigned rights by Earthwrx and the Uniify entities, the record did not provide sufficient information to determine whether there was subject matter jurisdiction. As such, the First Circuit ordered the parties to provide supplemental submissions and specifically ordered Gore to provide information about the citizenship of each alleged assignor. The parties complied with the First Circuit's order to file supplemental submissions. Gore posited that the court had adequate diversity jurisdiction. In so contending, it represented that, upon information and belief, Earthwrx was wholly owned by 541 LLC, an Oregon limited liability company with a principal place of business in Oregon. Gore also represented, again upon information and belief, that Uniify of Puerto Rico, a Puerto Rican entity, was wholly owned by Uniify Strategic Business Solutions LLC, a Louisiana company. However, Gore did not submit any evidence to support its position. Unsatisfied, the First Circuit remanded the case for jurisdictional fact-finding, specifically directing the district court to determine: (1) whether each individual subcontractor was completely diverse from the defendants and, if not; (2) whether the assignments to Gore were a collusive attempt to manufacture diversity jurisdiction in violation of Section 1359. Remand Proceedings On remand, the parties agreed to exchange written discovery and reserved the right to take depositions, but no party requested an evidentiary hearing and, instead, they opted to submit simultaneous briefs with accompanying evidence on the jurisdictional issues. In support of the contention that diversity jurisdiction exists for Earthwrx, Gore submitted a certificate of formation, allowing the district court to find that Earthwrx was a Puerto Rican company and James A. Young and Bobby Owens were listed as authorized persons, administrators and members of the LLC. The court determined that none of this information was helpful in assessing whether there was complete diversity between Earthwrx and the defendants. More problematic was that this evidence contradicted Gore's prior submission to the First Circuit that suggested Earthwrx was solely owned by 541 LLC. No documentation was provided to the district court regarding 541 LLC. While Gore did submit some additional public documentation obtained regarding property purchased by Earthwrx's members, it was plainly hearsay and unauthenticated. An email chain was also submitted, but there was no context for the statements therein, even though, according to Gore, its purported purpose was to show that the assignments were to consolidate claims, avoid unnecessary litigation costs and avoid inconsistent judgments. As for the Uniify entities, the court was only able to determine that Uniify was created on Nov. 18, 2017; that Terry Bee was listed as the president, administrator and authorized person for the LLC; and that Uniify Strategic was determined to be an inactive Louisiana LLC that included Bee and Joseph P. Meyer as officers. These findings once again conflicted with Gore's prior position before the First Circuit as it had previously reported that Uniify of Puerto Rico was wholly owned by Uniify Strategic, which, according to the district court, militated against Gore's position. As it had regarding Earthwrx, Gore submitted several additional documents that also ran afoul of the Federal Rules of Evidence in that they were inadmissible hearsay, unauthenticated, unreliable, speculative, inconsistent and simply not helpful to assessing diversity as of the date the action was filed. Outcome Given the foregoing, the U.S. District Court for the District of Puerto Rico was unable to accomplish the First Circuit's remand directive and could not analyze whether there was complete diversity between any of the alleged assignors-subcontractors and defendants — much less turn to the second question of examining the motive behind a particular assignment if there was not complete diversity between any particular assignor-subcontractor and the defendants. The First Circuit held that this was fatal to Gore's suit because it bore the burden of demonstrating the validity of the assignments, as the party seeking to invoke diversity jurisdiction. While Gore sought another remand to conduct additional discovery and seek an evidentiary hearing, the First Circuit refused to do so because Gore had already been given two opportunities to provide evidence of diversity and allowed seven months for the exact purpose of conducting discovery and seeking an evidentiary hearing. The case was dismissed. Key Lessons for Assignees Seeking to Invoke Diversity Jurisdiction If an assignee plans to invoke the diversity jurisdiction of a federal court, it cannot rely solely on the diversity of the parties to the action (if first filed in state court) or eventual action. Instead, the assignee ought to conduct a rigorous investigation into the citizenship of each and every assignor whose rights the assignee is asserting prior to bringing an action. Furthermore, assuming an assignor is an LLC, it is incumbent on the assignee to investigate the citizenship of all members of such entity.[3] If the members of a particular LLC are themselves unincorporated associations, then a deeper, iterative investigation is required; the citizenship of any member must be traced through "however many layers of members or partners there may be," according to the First Circuit's 2023 decision in BRT Management LLC v. Malden Storage LLC.[4] Assuming there is complete diversity of citizenship between the assignors and defendants, the assignee can — and should — allege that to guard against a court sua sponte raising an issue with subject matter jurisdiction midsuit or, worse, after years of litigation. Better yet, an assignee ought to have evidence at its disposal to establish the citizenship of each assignor at the time the action is filed, which is the only date that matters because diversity jurisdiction is determined as of that date.[5] A subsequent change in domicile for an assignor (or any party for that matter) will not defeat existence of diversity.[6] But an assignee should not have just any evidence — it should have evidence that would be admissible under the Federal Rules of Evidence to avoid authentication, hearsay or other admissibility problems. Additionally, an assignee should be able to explain how each piece of evidence supports the diversity analysis. Failure to do so may lead to a court determining it has not been provided with sufficient evidence, which may very well be fatal if the assignee is the one attempting to invoke the diversity jurisdiction as it would bear the burden of establishing subject matter jurisdiction once raised.[7] Should an opponent of assignment raise a Section 1359 challenge to the court's diversity jurisdiction, or if the court questions its subject matter jurisdiction, and the assignee is in the awkward position of not having sufficient information or evidence to make its showing, it ought to request sufficient time to conduct a rigorous investigation into the issues such that it is not in the position of having to rely on representations made on information and belief in the first instance and then later providing contradictory information or, worse yet, evidence. Doing so will not help the assignee's credibility and could raise the specter of sanctions under Rule 11 of the Federal Rules of Civil Procedure. Key Lessons for Nonassignee Opponents Conversely, a nonassignee should investigate any assignment-related allegations or disclosures thoroughly. If the non-assignee has a good faith basis to suspect that diversity jurisdiction exists only as the result of an assignment, then it should alert the federal court to the potential jurisdictional defect. This will force the assignee to provide the court with sufficient, admissible evidence that there was complete diversity at the commencement of the action and avoid an issue raised years later on appeal. If the assignee fails to do so, then the nonassignee ought to detail the deficiencies in the assignee's evidence and explain to the court how the assignee's burden has not been met. A Note on the Presumption of an Invalid Assignment If the district court on remand was unable to analyze whether there was complete diversity between any of Gore's assignor-subcontractors and the defendant (SLSCO) and its surety (Hartford Fire Insurance), that would have been the end of the analysis. However, if the district court determined that there was incomplete diversity between defendants and a particular assignor-subcontractor, then that assignment would have been presumptively ineffective for purposes of Section 1359.[8] While rebutting this presumption is "likely to be difficult," it is incumbent on the assignee-party to prove that it was not made collusively by way of a "credible showing of a legitimate reason for the transfer" that was "unrelated to the fabrication of federal court jurisdiction," according to the U.S. Court of Appeals for the Eighth Circuit's 2004 opinion in McCulloch v. Velez.[9] Given that credibility is in play to rebut this collusion presumption, live testimony likely will be advisable, if not absolutely necessary. Indeed, had the district court turned to the second question on remand, it telegraphed its displeasure with the documentary submission of an email that provided no context for the statements therein despite said email purporting to be evidence of a valid purpose for the assignments. Gore and Assocs. Mgmt. Co. v. SLSCO Ltd., --- F.4th ---, 2025 WL 2938795 (1st Cir. 2025). P.R. Laws Ann. Tit. 22, § 51. BRT Mgmt. LLC v. Malden Storage LLC, 68 F.4th 691, 696 (1st Cir. 2023) (internal quotation marks omitted). Id. Bank One, Texas, N.A. v. Montle, 964 F.2d 48, 49 (1st Cir. 1992). Id. E.g., Woo v. Spackman, 988 F.3d 47, 53 (1st Cir. 2021) (party who asserts jurisdiction bears burden of establishing that it exists by a preponderance of the evidence). McCulloch v. Velez, 364 F.3d 1, 6 (8th Cir. 2004). Id.

COVID-19 Business Interruption Cases Reach the End of the Road, with Mixed Results teaser
September 2, 2025

COVID-19 Business Interruption Cases Reach the End of the Road, with Mixed Results

Covering Appeals
Welcome to Robinson+Cole’s “Covering Appeals” Blog teaser
September 2, 2025

Welcome to Robinson+Cole’s “Covering Appeals” Blog

Covering Appeals
Hawai’i Supreme Court Applies Pollution Exclusion in CGL Case Involving Climate Change teaser
August 29, 2025

Hawai’i Supreme Court Applies Pollution Exclusion in CGL Case Involving Climate Change

Covering Appeals
February 28, 2025

Bases for Liability Under Chapter 93A—Principles of Unfairness and Deception

MCLE's Chapter 93A Rights and Remedies, 6th Edition

Contributing author for Chapter 2, "Bases for Liability Under Chapter 93A—Principles of Unfairness and Deception"

July 11, 2024

Construction Law Handbook, Fourth Edition

Contributing author

March 2024

Superb Motors v. Deo (E.D.N.Y.), Disqualification of Counsel Based Upon the Advocate-Witness Rule

Federal Magistrate Judge’s Association Bulletin
Spring 2022

Certification of Legal Questions to State Courts

Of Note column of Practical Law The Journal

Many states allow federal courts to certify a question to the state’s highest court when faced with a significant but unsettled question of state law, which affords the benefits of upholding principles of comity and increasing efficiency in the judicial process. However, while certification empowers those courts to provide an authoritative ruling on key state law issues, it is neither appropriate nor advantageous to seek certification in every case. In the Q&A-format article, Wystan explains the certification process, highlighting the procedure and practical considerations for parties seeking to obtain or prevent certification, and addresses the standard federal courts typically apply when considering an application to certify question to a state court, and the types of questions that are most – and least – appropriate for certification. View the article.

Welcome to Robinson+Cole’s “Covering Appeals” Blog teaser
September 2, 2025

Welcome to Robinson+Cole’s “Covering Appeals” Blog

Covering Appeals
Hawai’i Supreme Court Applies Pollution Exclusion in CGL Case Involving Climate Change teaser
August 29, 2025

Hawai’i Supreme Court Applies Pollution Exclusion in CGL Case Involving Climate Change

Covering Appeals
February 28, 2025

Bases for Liability Under Chapter 93A—Principles of Unfairness and Deception

MCLE's Chapter 93A Rights and Remedies, 6th Edition

Contributing author for Chapter 2, "Bases for Liability Under Chapter 93A—Principles of Unfairness and Deception"

July 11, 2024

Construction Law Handbook, Fourth Edition

Contributing author

March 2024

Superb Motors v. Deo (E.D.N.Y.), Disqualification of Counsel Based Upon the Advocate-Witness Rule

Federal Magistrate Judge’s Association Bulletin
Spring 2022

Certification of Legal Questions to State Courts

Of Note column of Practical Law The Journal

Many states allow federal courts to certify a question to the state’s highest court when faced with a significant but unsettled question of state law, which affords the benefits of upholding principles of comity and increasing efficiency in the judicial process. However, while certification empowers those courts to provide an authoritative ruling on key state law issues, it is neither appropriate nor advantageous to seek certification in every case. In the Q&A-format article, Wystan explains the certification process, highlighting the procedure and practical considerations for parties seeking to obtain or prevent certification, and addresses the standard federal courts typically apply when considering an application to certify question to a state court, and the types of questions that are most – and least – appropriate for certification. View the article.

News

April 20, 2026

Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

Law.com
April 7, 2026

Rhonda Tobin Among “Connecticut’s Most Influential Leaders”

Hartford Business Journal
February 9, 2026

Robinson+Cole Ushers in New Leadership for Nationally-Recognized Insurance + Reinsurance Practice

Seasoned insurance litigator Erica Kerstein tapped to champion the group’s next chapter
April 20, 2026

Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

Law.com
April 7, 2026

Rhonda Tobin Among “Connecticut’s Most Influential Leaders”

Hartford Business Journal
February 9, 2026

Robinson+Cole Ushers in New Leadership for Nationally-Recognized Insurance + Reinsurance Practice

Seasoned insurance litigator Erica Kerstein tapped to champion the group’s next chapter
January 14, 2026

Stephen Clancy Elected a Fellow of the American College of Coverage Counsel

American College of Coverage Counsel
January 5, 2026

Robinson+Cole Promotes New Partners and Counsel in Strategic Practices and Markets

Firm names three partners and eight counsel in New York, Boston, Hartford, Providence, and Stamford
December 3, 2025

Ray Gauvreau Authors Article on Diversity Jurisdiction

Law360 Expert Analysis
December 2, 2025

Eight Robinson+Cole Lawyers Named “Top Lawyers 2025”

Boston Magazine
Eight Robinson+Cole Lawyers Named “Top Lawyers 2025” teaser
November 14, 2025

Robinson+Cole Secures Top Rankings in 2026 Edition of Best Law Firms®

Firm earns 6 national and 46 first-tier rankings in Boston, Hartford, New York, Rhode Island, and Stamford Markets
Robinson+Cole Secures Top Rankings in 2026 Edition of Best Law Firms® teaser
November 6, 2025

Robinson+Cole Commends 62 Attorneys Recognized in 2025 Super Lawyers®

Recognition spans key regions and highlights the firm’s seasoned practitioners and emerging leaders in many business transactions and litigation practices
Robinson+Cole Commends 62 Attorneys Recognized in 2025 <i>Super Lawyers</i>® teaser
January 14, 2026

Stephen Clancy Elected a Fellow of the American College of Coverage Counsel

American College of Coverage Counsel
January 5, 2026

Robinson+Cole Promotes New Partners and Counsel in Strategic Practices and Markets

Firm names three partners and eight counsel in New York, Boston, Hartford, Providence, and Stamford
December 3, 2025

Ray Gauvreau Authors Article on Diversity Jurisdiction

Law360 Expert Analysis
December 2, 2025

Eight Robinson+Cole Lawyers Named “Top Lawyers 2025”

Boston Magazine
Eight Robinson+Cole Lawyers Named “Top Lawyers 2025” teaser
November 14, 2025

Robinson+Cole Secures Top Rankings in 2026 Edition of Best Law Firms®

Firm earns 6 national and 46 first-tier rankings in Boston, Hartford, New York, Rhode Island, and Stamford Markets
Robinson+Cole Secures Top Rankings in 2026 Edition of Best Law Firms® teaser
November 6, 2025

Robinson+Cole Commends 62 Attorneys Recognized in 2025 Super Lawyers®

Recognition spans key regions and highlights the firm’s seasoned practitioners and emerging leaders in many business transactions and litigation practices
Robinson+Cole Commends 62 Attorneys Recognized in 2025 <i>Super Lawyers</i>® teaser

Events

Upcoming

When the Entity Can’t Pay: The New Reality of Side-A Exposure

May 21 2026
Private & Non-For-Profit Directors & Officers Insurance ExecuSummit
Past

Assignment of Benefits: A Fraudster’s Playground

Mar 23 2026
PLRB 2026 Claims Conference
Upcoming

When the Entity Can’t Pay: The New Reality of Side-A Exposure

May 21 2026
Private & Non-For-Profit Directors & Officers Insurance ExecuSummit
Past

Assignment of Benefits: A Fraudster’s Playground

Mar 23 2026
PLRB 2026 Claims Conference
Past

Experts – Can’t Litigate With’em, Can’t Litigate Without’em: Building Credible Insurance Cases Through Expert Testimony

Mar 5 2026
2026 Florida Coverage College
Past

Arbitration, Mediation, Litigation, or Something Else? What is the Best Option for Your Matter and Why?

Mar 5 2026
2026 Insurance Coverage Litigation Committee CLE Seminar
Past

Coverage Trial Techniques: Trial set. What Now? The Evidence you Need or Don’t Need

Nov 20 2025
Florida Defense Lawyers Association’s (FDLA) Webinar Series
Past

NFIP Flood Coverage Techniques & Strategies

Jul 7 2025
Florida Defense Lawyers Association Webinar
Past

Experts – Can’t Litigate With’em, Can’t Litigate Without’em: Building Credible Insurance Cases Through Expert Testimony

Mar 5 2026
2026 Florida Coverage College
Past

Arbitration, Mediation, Litigation, or Something Else? What is the Best Option for Your Matter and Why?

Mar 5 2026
2026 Insurance Coverage Litigation Committee CLE Seminar
Past

Coverage Trial Techniques: Trial set. What Now? The Evidence you Need or Don’t Need

Nov 20 2025
Florida Defense Lawyers Association’s (FDLA) Webinar Series
Past

NFIP Flood Coverage Techniques & Strategies

Jul 7 2025
Florida Defense Lawyers Association Webinar

Firm Highlights

News
Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

News
Robinson+Cole Recognized at 2026 Women, Influence & Power in Law Awards
News
Julianna Charpentier Recognized as an “Up & Coming Lawyer”
News
Robinson+Cole’s People-First Culture Recognized in Vault’s 2027 Rankings
News
Robinson+Cole Names J. Michael Wirvin as Managing Partner

Robinson+Cole’s partnership has elected Boston Business Transactions Partner J. Michael Wirvin as its next Managing Partner, marking a pivotal moment in the firm’s 180-year history. Effective March 1, Wirvin will become the firm’s first Managing Partner based outside of Hartford, CT, reflecting Robinson+Cole’s continued evolution and expanding geographic footprint. His election underscores the firm’s deliberate, forward‑looking approach to leadership succession and long‑term strategic growth. Wirvin has served on Robinson+Cole’s Managing Committee since 2014, where he has played a central role in firm governance, strategic planning, and leadership succession, working closely with three managing partners through periods of unprecedented growth, market expansion, and changes in the legal industry. He is widely recognized for advising clients on complex domestic and cross‑border mergers and acquisitions, financings, and corporate structuring matters, with a particular focus on assisting U.S. and offshore companies navigate the legal, commercial, and cultural complexities of operating across jurisdictions. Wirvin also co‑chairs the firm’s International team. Wirvin has served as partner-in-charge of Robinson+Cole’s Boston office since 2014, reinforcing the firm’s culture, mentoring lawyers at all stages of their careers, and fostering cross‑disciplinary teamwork that strengthens client service. He recently helped lead the relocation of Robinson+Cole’s Boston office to 53 State Street, a premier downtown tower, creating a modern, light‑filled space designed to support employee well‑being with an energizing environment along with enhanced technology and workspaces that facilitate seamless remote and on-site collaboration and team building, while also promoting focused work. “It is a profound honor to be elected by my partners to serve as Managing Partner and lead this extraordinary team of lawyers and business professionals who raise the bar every day,” said Wirvin. “Our 180-year history is defined not merely by longevity, but by the trust we have earned, the results we have delivered, and the professionalism, mutual respect, and collegiality that have long defined our culture. As Managing Partner, I aim to build on that foundation—bringing strategic clarity and disciplined growth to our priorities, strengthening our national and international profile, investing in our people, and ensuring Robinson+Cole remains agile, cohesive, and well positioned to deliver practical, business‑minded solutions for clients in an increasingly complex and competitive environment.” Wirvin succeeds Rhonda J. Tobin, the firm’s first female Managing Partner, who led Robinson+Cole since 2021 and guided the firm through a period of significant transformation, growth, and innovation. Elected during the height of the COVID‑19 pandemic, Tobin brought to the role more than a decade of firm leadership experience, including service on the Managing Committee for 17 years and leadership of the firm’s Litigation Section for 14 years. During Tobin’s five-year tenure, Robinson+Cole successfully advanced and executed on a new Strategic Plan, improving profitability; expanding the firm’s New York, Boston, and Philadelphia offices; opening and growing offices in Washington, DC, and Austin, TX; and deepening leading national practices in affordable housing finance, bankruptcy, business transactions, capital markets and securities, intellectual property and technology, health care, managed care litigation, immigration, insurance, public finance, and real estate and development. Under Tobin’s leadership, the firm also strengthened its commitment to collaboration, inclusion, and talent development; launched meaningful DEIB initiatives; and made significant investments in technology, information governance, and workplace innovation. Additionally, the firm achieved top national rankings in Vault’s Best Law Firms to Work For six consecutive years. Robinson+Cole became the first Am Law 200 firm to strategically partner with agentic AI builder Newcode.ai and the first law firm in the United States to earn ARMA’s Verified Organization status, further reinforcing its position as an industry leader in innovation and information governance. Tobin’s leadership has been widely recognized, including being named Regional Managing Partner of the Year in Law.com’s 2025 New England Legal Awards and Managing Partner of the Year in the 2022 Women, Influence & Power in Law Awards. She will continue to serve as chair of the firm’s lateral growth committee and will continue her leadership roles and active involvement in Connecticut’s non-profit community and as Chairperson of the Connecticut Judicial Review Council. Commenting on Wirvin’s election, Tobin stated, “Mike’s deeply rooted presence and extensive leadership experience at Robinson+Cole make him an outstanding choice to lead our firm. I have known and worked closely with Mike for more than two decades, and there is no question that he is the right person to guide us forward as technological advancements and an evolving professional landscape present new opportunities. Mike is an exceptionally talented and experienced lawyer, and a trusted confidant whose insight I consistently relied on when facing strategic decisions. He is deeply respected by our lawyers and business professionals and brings a thoughtful, strategic perspective that will greatly benefit the firm. I look forward to the firm’s continued growth and success under his leadership.” Robinson+Cole also announced several additional leadership updates reflecting the firm’s continued focus on thoughtful succession planning, geographic expansion, and strategic growth. Davis Lee Wright, who is based in the firm’s Wilmington office, has been elected to the Managing Committee, joining Britt‑Marie K. Cole‑Johnson and Edward J. Heath who are resident in the Hartford office, Eric M. Kogan in Stamford, and Charles F. Martin III in Miami. The firm recently named New York partner Erica J. Kerstein as chair of its Insurance + Reinsurance group, Stamford partner Patrick W. Begos co-chair of its Managed Care + ERISA Litigation group, and Hartford partners  Conor O. Duffy and Robert S. Melvin and as Health Law group co-chair and Land Law Section co-chair, respectively. In addition, Kendra L. Berardi will succeed Wirvin as partner in charge of the Boston office.

News
Natalie Ramsey Honored with Prestigious 2026 David T. Sykes Award

Bankruptcy + Reorganizations group co-chair Natalie Ramsey was recognized as the 2026 David T. Sykes Award recipient at the Eastern District of Pennsylvania Bankruptcy Conference’s (EDPABC) 36th Annual Forum on February 26, 2026. The award, which was co-presented by the EDPABC and the Consumer Bankruptcy Assistance Project (CBAP), is named after renowned bankruptcy attorney David T. Sykes and reflects Natalie’s excellence and integrity as a bankruptcy attorney, unsurpassed professionalism, mentorship of younger professionals, upholding of the reputation of the local bankruptcy bar, unwavering dedication to the bankruptcy community and the less fortunate in Philadelphia, and courtesy and respect for all. Natalie has been a member of the EDPABC since 1991 and served on its Board of Directors from 1999 - 2006, including as Chair in 2006. In addition, she has also been a member of the CBAP since 1993 and served as its President from 2012 - 2013.

News
Capital Markets + Securities Group Represents D. Boral Capital, the Sole Book-Running Manager in Vernal Capital IPO

Robinson+Cole’s Capital Markets + Securities group represented D. Boral Capital, the sole book-running manager in the initial public offering (IPO) of Vernal Capital Acquisition Corp. (NYSE: VECA), a special purpose acquisition company incorporated in the Cayman Islands. D. Boral Capital is a relationship-driven global investment bank headquartered in New York City, dedicated to delivering strategic advisory and tailored financial solutions to middle-market and emerging growth companies. On May 7, 2026, VECA completed its $100 million IPO of 10,000,000 units at $10 per unit. The units began trading on the New York Stock Exchange under the ticker symbol “VECAU” on May 6, 2026. The team advising on the offering was led by Capital Markets + Securities group partner Arila Zhou and included members Ze'-ev Eiger and Emmett Tan. Read the press release.

News
Robinson+Cole Ushers in New Leadership for Nationally-Recognized Insurance + Reinsurance Practice

Robinson+Cole announced New York Partner Erica J. Kerstein has been named Chair of its Insurance + Reinsurance group, effective January 1, 2026. She succeeds Gregory P. Varga, who chaired the group since 2019. The strategic change to the leadership reinforces the firm’s thoughtful growth plan beyond its founding roots in Hartford and its commitment to providing exceptional client-focused service. “It’s a privilege to lead the firm’s nationally-recognized Insurance + Reinsurance group, a practice that has helped shape the insurance industry and this firm for generations,” said Kerstein. “Building on Greg’s leadership, I’m honored to carry this work forward and to do so as part of a team whose diversity and depth are a competitive advantage for our clients and their evolving needs navigating complex insurance coverage issues.” Celebrating over 180 years of practice, Robinson+Cole’s legacy in insurance law began alongside the establishment of leading insurance companies in the 19th century. The firm’s work was closely tied to these institutions, helping shape the legal landscape of the insurance industry from its earliest days. Over the decades, the firm’s lawyers have built a tradition of excellence and enduring relationships with leading insurers—a legacy now carried forward by more than 40 Insurance + Reinsurance lawyers practicing across six of Robinson+Cole’s office locations.   Insurance + Reinsurance group lawyers are helping to shape the insurance industry, representing and advising clients in disputes nationally and internationally involving cutting-edge issues, including on how to navigate the rapid evolution of artificial intelligence across the insurance ecosystem. As insurers accelerate their investment in artificial intelligence to address risk, efficiency, and regulatory complexity, Robinson+Cole has likewise made focused investments in AI‑enabled capabilities that enhance how its lawyers analyze data, manage complex matters, and deliver advice. Driven by client demand—including insurers seeking guidance on responsible, effective use of AI in claims, coverage, and litigation—the firm is integrating these technologies thoughtfully into its legal services while maintaining rigorous professional judgment, transparency, data security, and client confidentiality. Kerstein’s incisive, efficient, and responsive approach has enabled her to successfully litigate and arbitrate complex insurance matters—particularly in financial lines and commercial general liability, both domestically and internationally. Her experience also encompasses providing strategic counsel to clients in high-profile matters. Kerstein represents national and global insurers and reinsurers in state and federal courts across the United States, handling a wide range of complex coverage and bad faith disputes. Beyond her legal practice, Kerstein is an active member of The Bridge, an organization supporting the development of female talent in financial lines. “Greg Varga’s tenure as Chair of the firm’s Insurance practice has been exceptionally successful,” said Rhonda J. Tobin, Managing Partner at Robinson+Cole. “His vision, leadership, and experience not only elevated the practice and garnered national recognition, but it also opened new avenues for the firm’s growth and provides a strong foundation for Erica to carry forward.” Drawing on three decades of experience, Varga represents insurance companies in complex coverage and bad faith litigation, as well as arbitrations and appraisals. He chaired Robinson+Cole’s Insurance practice for 14 years over two terms, leading a team of more than 40 lawyers firmwide. Under his leadership, the group earned national recognition for its client-focused approach and became a thought leader in multiple areas of insurance law. “With Erica at the helm, our Insurance + Reinsurance group is poised to meet clients where they operate, extending our national and international reach,” said Varga. “Through working alongside her and leading the practice with her for the last few years, I am supremely confident that the group will continue to grow and thrive in the years to come as we continue to provide exceptional service to our valued clients. She will invest in data‑informed strategies, trial‑tested advocacy, and collaborative problem solving to keep our firm at the forefront of insurance law and practice.”

News
Robinson+Cole Remains A “Best Place to Work in Connecticut”
News
Robinson+Cole Integrates Thomson Reuters’ Deep Research into Newcode.ai Platform to Advance Secure, Verifiable Legal Research

Robinson+Cole has expanded its firmwide artificial intelligence (AI) capabilities by integrating Thomson Reuters’ Deep Research directly into Newcode.ai, the agentic AI platform implemented last year by the firm to support legal workflows across practices. With this integration, Robinson+Cole is one of only two law firms with direct access to the Deep Research API—and the only firm deploying it through Newcode.ai. Building on its 2025 partnership with Newcode.ai —making Robinson+Cole the first Am Law 200 firm to adopt the platform—the firm has continued to expand its AI capabilities as part of a broader strategy focused on secure deployment, ethical use, and seamless integration into daily legal work. The integration enables Robinson+Cole attorneys to conduct complex, multi‑step legal research and receive verifiable, citation‑backed responses grounded in trusted Thomson Reuters content. By embedding Deep Research into Newcode.ai, Robinson+Cole continues to build on its deliberate, governance‑first approach to AI adoption while delivering meaningful, practice‑ready innovation for its lawyers and clients. “Innovation at Robinson+Cole is grounded in client service, security, and practicality,” said J. Michael Wirvin, Managing Partner of Robinson+Cole. “By incorporating Thomson Reuters’ Deep Research directly into Newcode.ai, we are providing our lawyers with advanced research capabilities in a secure environment fully controlled by the firm that aligns with our standards for data governance, accuracy, and responsible AI use. This integration reflects our continued focus on adopting technology thoughtfully to support our attorneys and deliver value to our clients.” The addition of Deep Research allows attorneys to: Perform sophisticated legal research using agentic workflows that mirror real‑world legal reasoning Receive structured, verifiable responses grounded in Thomson Reuters data Streamline research processes while maintaining rigorous quality and accuracy standards Work entirely within Robinson+Cole’s firm‑controlled AI environment  “Our integration of the Thomson Reuters’ Deep Research API with Newcode represents a defining moment in our AI strategy,” said Chief Data Officer Jim Merrifield. "We are incredibly proud to be the first firm to bring this capability to life—unlocking the power of trusted legal data directly within the workflows our lawyers and business professionals rely on every day. This is exactly how we maximize our technology investments: by connecting best-in-class data sources through APIs into a unified platform, so the technology meets our people where they work, enhances their judgment, and accelerates better outcomes for our clients.” Robinson+Cole’s AI program is guided by firmwide policies, mandatory training, and ongoing oversight to ensure responsible use of emerging technologies. The firm’s approach emphasizes measured adoption, strong information governance, and alignment with client expectations, rather than one‑off experimentation. This latest enhancement underscores Robinson+Cole’s commitment to remaining forward‑thinking in its use of technology, while ensuring that innovation serves the firm’s clients, lawyers, and long‑term strategic goals.

News
Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

News
Robinson+Cole Recognized at 2026 Women, Influence & Power in Law Awards
News
Julianna Charpentier Recognized as an “Up & Coming Lawyer”
News
Robinson+Cole’s People-First Culture Recognized in Vault’s 2027 Rankings
News
Robinson+Cole Names J. Michael Wirvin as Managing Partner

Robinson+Cole’s partnership has elected Boston Business Transactions Partner J. Michael Wirvin as its next Managing Partner, marking a pivotal moment in the firm’s 180-year history. Effective March 1, Wirvin will become the firm’s first Managing Partner based outside of Hartford, CT, reflecting Robinson+Cole’s continued evolution and expanding geographic footprint. His election underscores the firm’s deliberate, forward‑looking approach to leadership succession and long‑term strategic growth. Wirvin has served on Robinson+Cole’s Managing Committee since 2014, where he has played a central role in firm governance, strategic planning, and leadership succession, working closely with three managing partners through periods of unprecedented growth, market expansion, and changes in the legal industry. He is widely recognized for advising clients on complex domestic and cross‑border mergers and acquisitions, financings, and corporate structuring matters, with a particular focus on assisting U.S. and offshore companies navigate the legal, commercial, and cultural complexities of operating across jurisdictions. Wirvin also co‑chairs the firm’s International team. Wirvin has served as partner-in-charge of Robinson+Cole’s Boston office since 2014, reinforcing the firm’s culture, mentoring lawyers at all stages of their careers, and fostering cross‑disciplinary teamwork that strengthens client service. He recently helped lead the relocation of Robinson+Cole’s Boston office to 53 State Street, a premier downtown tower, creating a modern, light‑filled space designed to support employee well‑being with an energizing environment along with enhanced technology and workspaces that facilitate seamless remote and on-site collaboration and team building, while also promoting focused work. “It is a profound honor to be elected by my partners to serve as Managing Partner and lead this extraordinary team of lawyers and business professionals who raise the bar every day,” said Wirvin. “Our 180-year history is defined not merely by longevity, but by the trust we have earned, the results we have delivered, and the professionalism, mutual respect, and collegiality that have long defined our culture. As Managing Partner, I aim to build on that foundation—bringing strategic clarity and disciplined growth to our priorities, strengthening our national and international profile, investing in our people, and ensuring Robinson+Cole remains agile, cohesive, and well positioned to deliver practical, business‑minded solutions for clients in an increasingly complex and competitive environment.” Wirvin succeeds Rhonda J. Tobin, the firm’s first female Managing Partner, who led Robinson+Cole since 2021 and guided the firm through a period of significant transformation, growth, and innovation. Elected during the height of the COVID‑19 pandemic, Tobin brought to the role more than a decade of firm leadership experience, including service on the Managing Committee for 17 years and leadership of the firm’s Litigation Section for 14 years. During Tobin’s five-year tenure, Robinson+Cole successfully advanced and executed on a new Strategic Plan, improving profitability; expanding the firm’s New York, Boston, and Philadelphia offices; opening and growing offices in Washington, DC, and Austin, TX; and deepening leading national practices in affordable housing finance, bankruptcy, business transactions, capital markets and securities, intellectual property and technology, health care, managed care litigation, immigration, insurance, public finance, and real estate and development. Under Tobin’s leadership, the firm also strengthened its commitment to collaboration, inclusion, and talent development; launched meaningful DEIB initiatives; and made significant investments in technology, information governance, and workplace innovation. Additionally, the firm achieved top national rankings in Vault’s Best Law Firms to Work For six consecutive years. Robinson+Cole became the first Am Law 200 firm to strategically partner with agentic AI builder Newcode.ai and the first law firm in the United States to earn ARMA’s Verified Organization status, further reinforcing its position as an industry leader in innovation and information governance. Tobin’s leadership has been widely recognized, including being named Regional Managing Partner of the Year in Law.com’s 2025 New England Legal Awards and Managing Partner of the Year in the 2022 Women, Influence & Power in Law Awards. She will continue to serve as chair of the firm’s lateral growth committee and will continue her leadership roles and active involvement in Connecticut’s non-profit community and as Chairperson of the Connecticut Judicial Review Council. Commenting on Wirvin’s election, Tobin stated, “Mike’s deeply rooted presence and extensive leadership experience at Robinson+Cole make him an outstanding choice to lead our firm. I have known and worked closely with Mike for more than two decades, and there is no question that he is the right person to guide us forward as technological advancements and an evolving professional landscape present new opportunities. Mike is an exceptionally talented and experienced lawyer, and a trusted confidant whose insight I consistently relied on when facing strategic decisions. He is deeply respected by our lawyers and business professionals and brings a thoughtful, strategic perspective that will greatly benefit the firm. I look forward to the firm’s continued growth and success under his leadership.” Robinson+Cole also announced several additional leadership updates reflecting the firm’s continued focus on thoughtful succession planning, geographic expansion, and strategic growth. Davis Lee Wright, who is based in the firm’s Wilmington office, has been elected to the Managing Committee, joining Britt‑Marie K. Cole‑Johnson and Edward J. Heath who are resident in the Hartford office, Eric M. Kogan in Stamford, and Charles F. Martin III in Miami. The firm recently named New York partner Erica J. Kerstein as chair of its Insurance + Reinsurance group, Stamford partner Patrick W. Begos co-chair of its Managed Care + ERISA Litigation group, and Hartford partners  Conor O. Duffy and Robert S. Melvin and as Health Law group co-chair and Land Law Section co-chair, respectively. In addition, Kendra L. Berardi will succeed Wirvin as partner in charge of the Boston office.

News
Natalie Ramsey Honored with Prestigious 2026 David T. Sykes Award

Bankruptcy + Reorganizations group co-chair Natalie Ramsey was recognized as the 2026 David T. Sykes Award recipient at the Eastern District of Pennsylvania Bankruptcy Conference’s (EDPABC) 36th Annual Forum on February 26, 2026. The award, which was co-presented by the EDPABC and the Consumer Bankruptcy Assistance Project (CBAP), is named after renowned bankruptcy attorney David T. Sykes and reflects Natalie’s excellence and integrity as a bankruptcy attorney, unsurpassed professionalism, mentorship of younger professionals, upholding of the reputation of the local bankruptcy bar, unwavering dedication to the bankruptcy community and the less fortunate in Philadelphia, and courtesy and respect for all. Natalie has been a member of the EDPABC since 1991 and served on its Board of Directors from 1999 - 2006, including as Chair in 2006. In addition, she has also been a member of the CBAP since 1993 and served as its President from 2012 - 2013.

News
Capital Markets + Securities Group Represents D. Boral Capital, the Sole Book-Running Manager in Vernal Capital IPO

Robinson+Cole’s Capital Markets + Securities group represented D. Boral Capital, the sole book-running manager in the initial public offering (IPO) of Vernal Capital Acquisition Corp. (NYSE: VECA), a special purpose acquisition company incorporated in the Cayman Islands. D. Boral Capital is a relationship-driven global investment bank headquartered in New York City, dedicated to delivering strategic advisory and tailored financial solutions to middle-market and emerging growth companies. On May 7, 2026, VECA completed its $100 million IPO of 10,000,000 units at $10 per unit. The units began trading on the New York Stock Exchange under the ticker symbol “VECAU” on May 6, 2026. The team advising on the offering was led by Capital Markets + Securities group partner Arila Zhou and included members Ze'-ev Eiger and Emmett Tan. Read the press release.

News
Robinson+Cole Ushers in New Leadership for Nationally-Recognized Insurance + Reinsurance Practice

Robinson+Cole announced New York Partner Erica J. Kerstein has been named Chair of its Insurance + Reinsurance group, effective January 1, 2026. She succeeds Gregory P. Varga, who chaired the group since 2019. The strategic change to the leadership reinforces the firm’s thoughtful growth plan beyond its founding roots in Hartford and its commitment to providing exceptional client-focused service. “It’s a privilege to lead the firm’s nationally-recognized Insurance + Reinsurance group, a practice that has helped shape the insurance industry and this firm for generations,” said Kerstein. “Building on Greg’s leadership, I’m honored to carry this work forward and to do so as part of a team whose diversity and depth are a competitive advantage for our clients and their evolving needs navigating complex insurance coverage issues.” Celebrating over 180 years of practice, Robinson+Cole’s legacy in insurance law began alongside the establishment of leading insurance companies in the 19th century. The firm’s work was closely tied to these institutions, helping shape the legal landscape of the insurance industry from its earliest days. Over the decades, the firm’s lawyers have built a tradition of excellence and enduring relationships with leading insurers—a legacy now carried forward by more than 40 Insurance + Reinsurance lawyers practicing across six of Robinson+Cole’s office locations.   Insurance + Reinsurance group lawyers are helping to shape the insurance industry, representing and advising clients in disputes nationally and internationally involving cutting-edge issues, including on how to navigate the rapid evolution of artificial intelligence across the insurance ecosystem. As insurers accelerate their investment in artificial intelligence to address risk, efficiency, and regulatory complexity, Robinson+Cole has likewise made focused investments in AI‑enabled capabilities that enhance how its lawyers analyze data, manage complex matters, and deliver advice. Driven by client demand—including insurers seeking guidance on responsible, effective use of AI in claims, coverage, and litigation—the firm is integrating these technologies thoughtfully into its legal services while maintaining rigorous professional judgment, transparency, data security, and client confidentiality. Kerstein’s incisive, efficient, and responsive approach has enabled her to successfully litigate and arbitrate complex insurance matters—particularly in financial lines and commercial general liability, both domestically and internationally. Her experience also encompasses providing strategic counsel to clients in high-profile matters. Kerstein represents national and global insurers and reinsurers in state and federal courts across the United States, handling a wide range of complex coverage and bad faith disputes. Beyond her legal practice, Kerstein is an active member of The Bridge, an organization supporting the development of female talent in financial lines. “Greg Varga’s tenure as Chair of the firm’s Insurance practice has been exceptionally successful,” said Rhonda J. Tobin, Managing Partner at Robinson+Cole. “His vision, leadership, and experience not only elevated the practice and garnered national recognition, but it also opened new avenues for the firm’s growth and provides a strong foundation for Erica to carry forward.” Drawing on three decades of experience, Varga represents insurance companies in complex coverage and bad faith litigation, as well as arbitrations and appraisals. He chaired Robinson+Cole’s Insurance practice for 14 years over two terms, leading a team of more than 40 lawyers firmwide. Under his leadership, the group earned national recognition for its client-focused approach and became a thought leader in multiple areas of insurance law. “With Erica at the helm, our Insurance + Reinsurance group is poised to meet clients where they operate, extending our national and international reach,” said Varga. “Through working alongside her and leading the practice with her for the last few years, I am supremely confident that the group will continue to grow and thrive in the years to come as we continue to provide exceptional service to our valued clients. She will invest in data‑informed strategies, trial‑tested advocacy, and collaborative problem solving to keep our firm at the forefront of insurance law and practice.”

News
Robinson+Cole Remains A “Best Place to Work in Connecticut”
News
Robinson+Cole Integrates Thomson Reuters’ Deep Research into Newcode.ai Platform to Advance Secure, Verifiable Legal Research

Robinson+Cole has expanded its firmwide artificial intelligence (AI) capabilities by integrating Thomson Reuters’ Deep Research directly into Newcode.ai, the agentic AI platform implemented last year by the firm to support legal workflows across practices. With this integration, Robinson+Cole is one of only two law firms with direct access to the Deep Research API—and the only firm deploying it through Newcode.ai. Building on its 2025 partnership with Newcode.ai —making Robinson+Cole the first Am Law 200 firm to adopt the platform—the firm has continued to expand its AI capabilities as part of a broader strategy focused on secure deployment, ethical use, and seamless integration into daily legal work. The integration enables Robinson+Cole attorneys to conduct complex, multi‑step legal research and receive verifiable, citation‑backed responses grounded in trusted Thomson Reuters content. By embedding Deep Research into Newcode.ai, Robinson+Cole continues to build on its deliberate, governance‑first approach to AI adoption while delivering meaningful, practice‑ready innovation for its lawyers and clients. “Innovation at Robinson+Cole is grounded in client service, security, and practicality,” said J. Michael Wirvin, Managing Partner of Robinson+Cole. “By incorporating Thomson Reuters’ Deep Research directly into Newcode.ai, we are providing our lawyers with advanced research capabilities in a secure environment fully controlled by the firm that aligns with our standards for data governance, accuracy, and responsible AI use. This integration reflects our continued focus on adopting technology thoughtfully to support our attorneys and deliver value to our clients.” The addition of Deep Research allows attorneys to: Perform sophisticated legal research using agentic workflows that mirror real‑world legal reasoning Receive structured, verifiable responses grounded in Thomson Reuters data Streamline research processes while maintaining rigorous quality and accuracy standards Work entirely within Robinson+Cole’s firm‑controlled AI environment  “Our integration of the Thomson Reuters’ Deep Research API with Newcode represents a defining moment in our AI strategy,” said Chief Data Officer Jim Merrifield. "We are incredibly proud to be the first firm to bring this capability to life—unlocking the power of trusted legal data directly within the workflows our lawyers and business professionals rely on every day. This is exactly how we maximize our technology investments: by connecting best-in-class data sources through APIs into a unified platform, so the technology meets our people where they work, enhances their judgment, and accelerates better outcomes for our clients.” Robinson+Cole’s AI program is guided by firmwide policies, mandatory training, and ongoing oversight to ensure responsible use of emerging technologies. The firm’s approach emphasizes measured adoption, strong information governance, and alignment with client expectations, rather than one‑off experimentation. This latest enhancement underscores Robinson+Cole’s commitment to remaining forward‑thinking in its use of technology, while ensuring that innovation serves the firm’s clients, lawyers, and long‑term strategic goals.

News
Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

News
Robinson+Cole Recognized at 2026 Women, Influence & Power in Law Awards
News
Julianna Charpentier Recognized as an “Up & Coming Lawyer”
News
Robinson+Cole’s People-First Culture Recognized in Vault’s 2027 Rankings
News
Robinson+Cole Names J. Michael Wirvin as Managing Partner

Robinson+Cole’s partnership has elected Boston Business Transactions Partner J. Michael Wirvin as its next Managing Partner, marking a pivotal moment in the firm’s 180-year history. Effective March 1, Wirvin will become the firm’s first Managing Partner based outside of Hartford, CT, reflecting Robinson+Cole’s continued evolution and expanding geographic footprint. His election underscores the firm’s deliberate, forward‑looking approach to leadership succession and long‑term strategic growth. Wirvin has served on Robinson+Cole’s Managing Committee since 2014, where he has played a central role in firm governance, strategic planning, and leadership succession, working closely with three managing partners through periods of unprecedented growth, market expansion, and changes in the legal industry. He is widely recognized for advising clients on complex domestic and cross‑border mergers and acquisitions, financings, and corporate structuring matters, with a particular focus on assisting U.S. and offshore companies navigate the legal, commercial, and cultural complexities of operating across jurisdictions. Wirvin also co‑chairs the firm’s International team. Wirvin has served as partner-in-charge of Robinson+Cole’s Boston office since 2014, reinforcing the firm’s culture, mentoring lawyers at all stages of their careers, and fostering cross‑disciplinary teamwork that strengthens client service. He recently helped lead the relocation of Robinson+Cole’s Boston office to 53 State Street, a premier downtown tower, creating a modern, light‑filled space designed to support employee well‑being with an energizing environment along with enhanced technology and workspaces that facilitate seamless remote and on-site collaboration and team building, while also promoting focused work. “It is a profound honor to be elected by my partners to serve as Managing Partner and lead this extraordinary team of lawyers and business professionals who raise the bar every day,” said Wirvin. “Our 180-year history is defined not merely by longevity, but by the trust we have earned, the results we have delivered, and the professionalism, mutual respect, and collegiality that have long defined our culture. As Managing Partner, I aim to build on that foundation—bringing strategic clarity and disciplined growth to our priorities, strengthening our national and international profile, investing in our people, and ensuring Robinson+Cole remains agile, cohesive, and well positioned to deliver practical, business‑minded solutions for clients in an increasingly complex and competitive environment.” Wirvin succeeds Rhonda J. Tobin, the firm’s first female Managing Partner, who led Robinson+Cole since 2021 and guided the firm through a period of significant transformation, growth, and innovation. Elected during the height of the COVID‑19 pandemic, Tobin brought to the role more than a decade of firm leadership experience, including service on the Managing Committee for 17 years and leadership of the firm’s Litigation Section for 14 years. During Tobin’s five-year tenure, Robinson+Cole successfully advanced and executed on a new Strategic Plan, improving profitability; expanding the firm’s New York, Boston, and Philadelphia offices; opening and growing offices in Washington, DC, and Austin, TX; and deepening leading national practices in affordable housing finance, bankruptcy, business transactions, capital markets and securities, intellectual property and technology, health care, managed care litigation, immigration, insurance, public finance, and real estate and development. Under Tobin’s leadership, the firm also strengthened its commitment to collaboration, inclusion, and talent development; launched meaningful DEIB initiatives; and made significant investments in technology, information governance, and workplace innovation. Additionally, the firm achieved top national rankings in Vault’s Best Law Firms to Work For six consecutive years. Robinson+Cole became the first Am Law 200 firm to strategically partner with agentic AI builder Newcode.ai and the first law firm in the United States to earn ARMA’s Verified Organization status, further reinforcing its position as an industry leader in innovation and information governance. Tobin’s leadership has been widely recognized, including being named Regional Managing Partner of the Year in Law.com’s 2025 New England Legal Awards and Managing Partner of the Year in the 2022 Women, Influence & Power in Law Awards. She will continue to serve as chair of the firm’s lateral growth committee and will continue her leadership roles and active involvement in Connecticut’s non-profit community and as Chairperson of the Connecticut Judicial Review Council. Commenting on Wirvin’s election, Tobin stated, “Mike’s deeply rooted presence and extensive leadership experience at Robinson+Cole make him an outstanding choice to lead our firm. I have known and worked closely with Mike for more than two decades, and there is no question that he is the right person to guide us forward as technological advancements and an evolving professional landscape present new opportunities. Mike is an exceptionally talented and experienced lawyer, and a trusted confidant whose insight I consistently relied on when facing strategic decisions. He is deeply respected by our lawyers and business professionals and brings a thoughtful, strategic perspective that will greatly benefit the firm. I look forward to the firm’s continued growth and success under his leadership.” Robinson+Cole also announced several additional leadership updates reflecting the firm’s continued focus on thoughtful succession planning, geographic expansion, and strategic growth. Davis Lee Wright, who is based in the firm’s Wilmington office, has been elected to the Managing Committee, joining Britt‑Marie K. Cole‑Johnson and Edward J. Heath who are resident in the Hartford office, Eric M. Kogan in Stamford, and Charles F. Martin III in Miami. The firm recently named New York partner Erica J. Kerstein as chair of its Insurance + Reinsurance group, Stamford partner Patrick W. Begos co-chair of its Managed Care + ERISA Litigation group, and Hartford partners  Conor O. Duffy and Robert S. Melvin and as Health Law group co-chair and Land Law Section co-chair, respectively. In addition, Kendra L. Berardi will succeed Wirvin as partner in charge of the Boston office.

News
Natalie Ramsey Honored with Prestigious 2026 David T. Sykes Award

Bankruptcy + Reorganizations group co-chair Natalie Ramsey was recognized as the 2026 David T. Sykes Award recipient at the Eastern District of Pennsylvania Bankruptcy Conference’s (EDPABC) 36th Annual Forum on February 26, 2026. The award, which was co-presented by the EDPABC and the Consumer Bankruptcy Assistance Project (CBAP), is named after renowned bankruptcy attorney David T. Sykes and reflects Natalie’s excellence and integrity as a bankruptcy attorney, unsurpassed professionalism, mentorship of younger professionals, upholding of the reputation of the local bankruptcy bar, unwavering dedication to the bankruptcy community and the less fortunate in Philadelphia, and courtesy and respect for all. Natalie has been a member of the EDPABC since 1991 and served on its Board of Directors from 1999 - 2006, including as Chair in 2006. In addition, she has also been a member of the CBAP since 1993 and served as its President from 2012 - 2013.