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212199P.pdf   06/06/2022  Planet Sub Holdings, Inc.  v.  State Auto Property & Casualty
   U.S. Court of Appeals Case No:  21-2199
   U.S. District Court for the Western District of Missouri - Kansas City   
   [PUBLISHED] [Benton, Author, with Smith, Chief Judge, and Kelly, Circuit 
   Judge] 
   Civil case - COVID. In suit seeking recovery for business losses caused by 
   closures under COVID-19 public orders, plaintiffs could not show the 
   direct physical loss of or damage to property required for recovery - see 
   Monday Restaurants v. Intrepid Ins. Co. 32 F.4th 656, 658 (8th Cir. 2022); 
   nor were the losses covered by a provision providing coverage for closures 
   related to food-borne illness; finally, the Civil Authority provision of 
   the policy requires a direct physical loss or damage to property.