Lennar Corp. v. Auto-Owners Ins. Co
In Lennar Corp. v. Auto-Owners Ins. Co., 214 Ariz. 255, 151 P.3d 538 (App. 2007), the Court held that "the requirement that a contractor indemnify a developer is not an agreement that the contractor obtain insurance that could provide a defense for the developer." Id. at 267,45, 151 P.3d at 550.
The contract at issue in Lennar did not contain a provision specifying additional obligations; nor were there writings and conduct evidencing an agreement to add the contracting developer as an additional insured on the contractor's insurance policies.
In Lennar, the Court noted that this type of dispute can be avoided if a contract between a contractor and subcontractor includes more specific language delineating additional-insured status. 214 Ariz. at 268 n.15, 151 P.3d at 551 n.15