Discrimination Exclusion Unambiguously Bars Coverage For Lawsuit Alleging A Racially-Motivated Campaign Interfered With Claimant's Business

The United States District Court for the Southern District of Florida, applying Florida law, has held that a discrimination exclusion barred coverage for a lawsuit against a city chamber of commerce for allegedly interfering with a contract between a Muslim federation and a hotel as part of a "racially-motivated" campaign. Parkland Chamber of Comm. v. Mt. Vernon Fire Ins. Co., 2025 WL3214313 (S.D. Fla. Nov. 18, 2025).

A Muslim federation sued the insured city chamber of commerce for allegedly interfering with a contract between the federation and a hotel to host the federation's second annual conference. According to the federation, the chamber of commerce engaged in multiple efforts aimed at pressuring the hotel to cancel the contract, which the federation alleged was part of a "racially-motivated" campaign. The federation asserted causes of action for unlawful discrimination under 42 U.S.C. §2000(a), unlawful discrimination under 42 U.S.C. §1981, conspiracy to interfere with civil rights in violation of §1985, breach of contract, and tortious interference with a business relationship.

The city chamber of commerce tendered the lawsuit to its management liability insurer for coverage. The insurer denied coverage based on the policy's discrimination exclusion, which excluded coverage for claims "arising out of" discrimination, including but not limited to discrimination based on religion and race.

In the ensuing coverage litigation, the parties filed cross-motions for summary judgment regarding the application of the discrimination exclusion. In granting the insurer's motion and denying the insured's motion, the court held that the discrimination exclusion was unambiguous and barred coverage in full. Rejecting the insured's argument that the tortious interference cause of action was not excluded, the court highlighted the exclusion's broad lead-in language excluding coverage for any claims "arising out of" discrimination. Because the federation alleged that the insured's conduct was connected to a racially-motivated campaign, the court concluded that the discrimination exclusion applied to all causes of action, including the tortious interference claim.

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