SAN FRANCISCO - The Ninth Circuit U.S. Court of Appeals on April 15 held that there is no directors and officers (D&O) liability coverage for underlying allegations that an insured violated California Military and Veterans Code Section 394 and the Uniformed Services Employment and Reemployment Rights Act when it fired an employee (Forest Meadows Owners Assoc. v. State Farm General Insurance Co., No. 12-16073, 9th Cir.; 2014 U.S. App. LEXIS 6993).