Mealey's (March 1, 2017, 12:26 PM EST) -- PHILADELPHIA — A Pennsylvania judge on Jan. 20 found that a commercial umbrella liability insurer has no duty to indemnify its insured against $2.6 million in punitive damages that it paid to settle an underlying wrongful death and survival action, finding that consistent with Pennsylvania law and public policy, punitive damages based on the insured’s direct liability may not be insured and, as a result, are not recoverable (Bensalem Racing Association, Inc., et al. v. Ace Property and Casualty Insurance Co., No. 4858, Pa. Comm. Pls., Philadelphia Co., 2017 Phila. Ct. Com. Pl. LEXIS 11)....