'Partridge' family reunion: California v. Allstate

I saw this opinion, California v. Allstate, a couple days ago but other things interfered with blogging about it until now. This is a case about coverage for environmental pollution under the "sudden and unexpected" language found in old liability policies, and that is an interesting thing in itself, but what chiefly interested me about this case was the extended discussion of the Partridge case, an influential case that, in days gone by, was in part responsible for the creation of the modern anti-concurrent cause language found in first party policies. Partridge is not a first party case, of course, but its reasoning resonated beyond the third party liability context, as I discussed in this Appleman's Critical Issues article on anti-concurrent causation analysis fr