SPOKANE, Wash. - A Washington federal judge on Nov. 13 determined that two insurers breached their duty to defend an insured in an underlying environmental contamination action because a potential for coverage exists under the policies and the pollution exclusion does not necessarily preclude coverage (Newmont USA Ltd., et al. v. American Home Assurance Co., et al., No. 09-33, E.D. Wash.; 2009 U.S. Dist. LEXIS 106585). From Mealey's Litigation Report: Insurance