Champlain Specialty Insurance Company wants a federal court to declare it owes nothing in a Texas wrongful-death suit - and its case rests on its own policy.
In a complaint for declaratory judgment filed June 17, 2026, in the Northern District of Texas, Champlain argues it has no duty to defend or indemnify its insured, Code 3 Investigations and Security, LLC. A declaratory judgment is simply a court ruling on a party's obligations before any money changes hands.
The fight grows out of a state-court suit filed December 23, 2025, in Dallas County. According to that petition, Drew Knowles was approached and fatally shot in his vehicle on June 26, 2025, by two men the filing describes as "acting as bounty hunters for Code 3." The pair had confronted Knowles to serve a warrant "for theft and fraud."
The petition alleges the men stalked Knowles, boxed in his car, and opened fire as he tried to drive away, "despite a lack of an imminent threat to their safety." It says their state armed security licenses had expired in May 2025, and that both were "charged with murder," with bonds set at $500,000 each. The two men are named in the state petition but are not defendants in Champlain's coverage suit.
For claims professionals, the value is in how Champlain builds its exit. It points to an endorsement and three exclusions.
The first is a "Classification Limitation - Your Work" endorsement, which covers only one scheduled category: "Security and Patrol Operations." Anything else, it says, is "excluded from coverage under this policy." Champlain argues bounty hunting and warrant work don't qualify.
The next bars injury "arising out of any actual or alleged violation of any criminal or penal statutes or ordinances." Another strips coverage for firearm discharge by anyone other than an "Authorized Firearm" user - a status the policy ties to being "properly licensed, if applicable, and trained," which speaks directly to the expired-license claim. The last excludes punitive or exemplary damages, which the underlying plaintiffs are seeking.
Champlain also issued an excess policy for the same one-year term, and the complaint says it "follows the terms and conditions of the Primary Policy." The underlying plaintiffs seek more than $1,000,000.
None of the allegations have been tested in court. Champlain's filing asks a court to declare its coverage obligations; it is not itself a ruling. No court has decided the underlying wrongful-death claims or whether Champlain owes a defense.
