Extract to table

This burden-shifting framework reflects the well-settled Texas rule that exclusionary clauses in insurance policies are to be narrowly construed, and that any ambiguity in an exclusion must be resolved in favor of coverage

Both the storage-practice element and the causal element must be established by the insurer

First, the insured must have "fail[ed] to maintain" fire protection, detection, or suppression systems "in accordance with applicable codes and manufacturer specifications

" Second, the loss or damage must have been "caused by or resulting from" that failure

The phrase "caused by or resulting from" imposes an express causal-nexus requirement — the maintenance failure must be a proximate cause of the loss

Even if the two-month delay in the annual full-flow test could be characterized as a "failure to maintain" — a characterization that SLG disputes — Meridian must separately establish that this failure "caused or resulted in" the loss