The Second Appellate District affirmed a judgment of dismissal. The court held that an employer was not an “additional insured” entitled to a defense under a charitable nonprofit corporation’s commercial general liability policy where an employee sought recovery for personal injuries sustained while performing volunteer work on behalf of the nonprofit organization.

Nonprofit corporation Christmas in April USA (CIA) enlisted volunteers to repair homes of low-income and elderly persons. CIA solicited companies such as The Boeing Company to encourage its employees to volunteer for such construction projects.