Ryder Integrated Logistics v. BellSouth Telecommunications

In Ryder Integrated Logistics v. BellSouth Telecommunications, 277 Ga. App. 679 (627 SE2d 358) (2006), rev'd in part on other grounds, 281 Ga. 736 (642 SE2d 695) (2007), the Court relied upon the specific language of the contract between the parties to conclude that the parties did not intend to name BellSouth as an additional insured on the excess policy procured by Ryder. Id. at 686 (4) (b). The contractual language in Ryder Integrated Logistics, however, was dramatically different from the "all policies" language used in Paragraph 5 of the Subcontract. Specifically, the contract in that case stated: "All commercial general liability policies required herein shall name (BellSouth) as an additional insured with respect to work performed under this contract." Id. at 681. As such, in Ryder Integrated Logistics it was clear that the parties intended to limit additional insured coverage to the specific insurance required in the parties' contract.