Coca Cola Bottling Co. v. Columbia Casualty Ins. Co

In Coca Cola Bottling Co. v. Columbia Casualty Ins. Co. (1992) 11 Cal.App.4th at p. 1182, after the excess policy set its monetary limit at $ 5 million, it stated: "'CSL each occurrence and annual aggregate where applicable excess of primaries.'" (Id. at p. 1183.) The court held: "Because the excess policy does not itself fully define the lower limits of its coverage, reference to the terms of the underlying policy is necessary. " (Id. at p. 1183.) "As a practical matter the excess policy cannot be interpreted without reference to the appropriate section . . . of the underlying policy." (Id. at p. 1184.)