NEW ORLEANS - An insurer has a duty to defend its insured for injuries sustained as a result of a collision of two vessels because the insurer failed to prove that the accident occurred outside of the policy's navigational limits and that the insured misrepresented how the vessel would be used, a Louisiana federal judge said Oct. 10 (Tyrone Walton v. ES&H Inc., No. 11-1819, E.D. La.; 2013 U.S. Dist. LEXIS 146851).