Making an Erie guess about Louisiana insurance law, the Fifth Circuit held: “Consistent with our decision in Terry Black’s, and the decisions of the unanimous circuit courts, we conclude, pursuant to Louisiana law, that losses caused by civil authority orders closing nonessential businesses in response to the COVID-19 pandemic do not fall within the meaning of ‘direct physical loss of or damage to property.’” Q Clothier v. Twin City Fire Ins., No. 21-30278 (March 22, 2022).

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