Landlord's Insurer Can't Seek Subrogation from Tenant

 Facts: A landlord and a tenant signed a lease that provided that the landlord would insure the building and the tenant would insure its personal property inside the building. When the property was later damaged by a fire, the landlord’s insurance covered the loss. The landlord’s insurer later filed a subrogation action—that is, a claim to be reimbursed—against the tenant to recover the amount it had paid to the landlord.