A court appointed receiver for a nonprofit community action program may claim breach of duty by two former officers and demand that the organization’s D & O insurance carrier make payment. A federal District Court in Rhode Island, reviewing conflicting cases in other jurisdictions, has held that the claim is not excluded by the “insured-versus-insured” exception contained in the policy. The Providence Community Action Program purchased a directors and officers liability policy entitled “Flexi Plus Five” in 2011 from the Philadelphia Indemnity Insurance Company. Shortly thereafter, the organization experienced financial difficulty and was forced into receivership. Its certificate of...