A missing USPS mailing certificate left Travelers responsible for workers’ comp coverage, after Alaska’s Supreme Court ruled against the insurer on June 27, 2025.
Travelers Property Casualty Company of America provided Keluco General Contractors, Inc. with a workers’ compensation and employers’ liability policy that ran from March 15, 2016, to March 5, 2017. Before the policy expired, Travelers said it sent a renewal notice to Keluco and its insurance agent, Gretchen Santerre. But Keluco said it never received the notice. And here’s the key point: Travelers didn’t get a certificate of mailing from the U.S. Postal Service, which Alaska law requires for nonrenewal notices.
Under Alaska law, when an insurer doesn’t plan to renew a policy, it must send written notice by first-class mail and get a USPS certificate of mailing. The policy itself included an Alaska Cancellation and Nonrenewal Endorsement that made following these requirements part of the contract. Since Travelers didn’t meet that requirement, the law treated the policy as still in effect when the injury happened.
In September 2017, a Keluco employee was injured on the job. That’s when Keluco found out its policy had lapsed - at least that’s what it believed at the time. The State of Alaska pursued penalties for not having workers’ compensation insurance, and the employee filed a claim. Keluco sued Santerre and her employer, and later added direct claims against Travelers.
The Alaska Supreme Court upheld the lower court’s ruling that Travelers had breached the contract because it didn’t follow the required mailing process. That meant the policy was still active when the injury occurred, and Travelers owed coverage. The court did change one part of the decision: prejudgment interest should start from the date of the injury, September 20, 2017, not from when the mailing failed.
For insurers, this case is a clear reminder: missing a basic mailing step can lead to unexpected obligations and costly litigation.
