The U.S. Court of Appeals for the Tenth Circuit’s just-issued decision Church of Jesus Christ of Latter-Day Saints v. National Union Fire Insurance Company of Pittsburgh, PA, et al., has established an important new tool for general liability insurance policyholders facing vexing problems involving liability for patterns of multiple harm arising from the same general circumstances or conditions, like sex abuse cases. The court determined that the standard CGL “occurrence” definition is ambiguous and must therefore be interpreted in whichever manner maximizes coverage for the policyholder.