The United States District Court for the Southern District of Florida, applying Florida law, has held that a professional liability insurer did not have a duty to defend or indemnify its insured in a lawsuit involving the improper transfer of escrow funds, based on the policy’s exclusion for claims arising out of the misappropriation of funds. Hanover Ins. Co. v. Ross, No. 23-CV-80829, 2024 WL 2976762 (S.D. Fla. June 13, 2024). The court also held, however, that the insurer had a duty to defend the insured in a separate lawsuit alleging intentional torts tangentially arising out of the same transaction.