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3694 REVIEW GRANTED Under CGL policies issued prior to 1986, the duty to defend against claims for pollution damage is restricted to civil actions initiated in a court and does not include administrative proceedings; under CGL policies issued after 1986 and containing absolute pollution exclusions, there is no coverage at all for damage resulting from the release of contaminants.CitationCDM v AMERICAN NAT'L (Pollution Coverage) 112 CA4 791 [See: FosterGardner v Nat'l Union 18 C4 857, T/AT 9/98; Lloyd's v Superior Court 24 C4 945, T/AT 3/01]
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