Mealey's (July 31, 2019, 10:47 AM EDT) -- PHILADELPHIA — The Third Circuit U.S. Court of Appeals on July 30 remanded a district court’s ruling in favor of an excess insurer in an environmental contamination coverage dispute after determining that the lower court must consider whether a primary insurer’s payment for claims arising out of one of three landfills applied to all of the landfills and exhausted the primary insurer’s limits under a 1982 primary policy (Penn National Insurance Co. v. North River Insurance Co., et al., No. 18-2687, 3rd Cir., 2019 U.S. App. LEXIS 22561)....