ST. LOUIS - The Eighth Circuit U.S. Court of Appeals on Nov. 18 affirmed a lower federal court's finding that coverage for underlying claims against a title insurance company insured and its employees is barred by a professional liability insurance policy's customer funds exclusion (Charles E. Bethel II, et al. v. Darwin Select Insurance Co., No. 12-3528, 8th Cir.; 2013 U.S. App. LEXIS 23183).