BATON ROUGE, La. - Although the extent of an insurer's duty to defend still must be decided, a Louisiana federal judge on April 28 ruled that it is clear from the underlying lawsuit filed against the insured that the insurer had a duty to defend (PCS Nitrogen Fertilizer LP v. American Home Assurance Co., No. 13-170, M.D. La.; 2014 U.S. Dist. LEXIS 58592).