Verdict for insured overturned, based on language from previous policy

In Zaremba Equipment, Inc. v. Harco National Insurance, the Court of Appeals partially over-turned a jury verdict for the plaintiff insured.  Zaremba had claimed that it was underinsured for the value of a building that burned, and alleged that the insurer and its agent should be responsible for failing to provide "full coverage".  The Court held that an agent who undertakes to provide "full coverage" owes a duty to his customer, and that this duty can be proved without the benefit of an insurance expert.  It also held, however, that the agent and insurer should have been allowed to prove that the prior insurance contract explained to the victim that his "replacement coverage" was limited to a policy maximum, even though the insured had never been provided with a copy of his current policy with the similar language that the insurer was attempting to enforce.