(March 1, 2019, 1:40 PM EST) -- RICHMOND, Va. — The Fourth Circuit U.S. Court of Appeals on Feb. 28 found that Virginia Code § 38.2-2226 does not apply to an insurer’s denial of coverage for an underlying $910,148 default judgment entered against its design company insured, finding the insurer may deny coverage despite the insurer’s failure to give the plaintiff notice of the insured’s late reporting of the claim (Gateway Residences at Exchange, LLC v. Illinois Union Insurance Company, No. 18-1491, 4th Cir., 2019 U.S. App. LEXIS 6044)....