By Alexander Bandza and Brian Scarbrough ( November 9, 2018, 9:45 AM EST) -- The Massachusetts federal district court's decision reinforces two important policyholder concepts in obtaining coverage for environmental contamination. First, a policyholder, faced with a complaint containing general allegations of negligent pollutant releases, need not prove that the "sudden and accidental" exception to the pollution exclusion applies to show that the insurer owes a duty to defend. Second, the "sudden and accidental" exception is highly fact-specific. Here, even though it was undisputed that the dry cleaning operation used perchlorethylene and that it overflowed on several occasions, causing contamination at the site, the court rejected the insurer's motion for summary judgment, holding it did not meet its burden because the releases could still be considered "sudden and accidental" in this particular context....