On March 3, 2021, the Delaware Supreme Court (the Court) in RSUI Indemnity Co. v. Murdock issued an important decision concerning various coverage issues under directors and officers liability (D&O) policies. The decision ends years of litigation (the Dole litigation) concerning insurer obligations for settlements of (i) litigation in which two executives of Dole Food Co. (Dole) were found to have fraudulently induced Dole to permit one of them to take the company private at an unfairly low price, and (ii) a follow-on securities fraud suit based on the same wrongful conduct.