applies, if a "collapse" occurred from specified causes (including defective methods in construction), the Policy covers Masonic Temple's damage. As such, in order to deny coverage in good faith, Indiana Farmers must have rested its decision on a rational contention that earth movement as contemplated by the policy occurred AND that no collapse occurred. Indiana Farmers asserts, and Masonic Temple agrees, that no Indiana cases have specifically defined either the phrase "earth movement" or the term "collapse" contained within a commercial insurance policy. With respect to interpretations of the term "collapse," both Masonic Temple and Indiana Farmers acknowledge a split of authority in other jurisdictions. See e.g., American Concept Ins. Co. v. Jones, 985 F.Supp. 1220 (D.Utah 1996) (<HOLDING>) and Williams v. State Farm Fire & Cas. Co.,
holding error was structural because of the difficulty of assessing the effect of the error holding that a substantial structural failure short of collapse to rubble is a collapse recognizing categorical approach to structural errors that presumptively satisfy the third prong of olano and listing classes of cases that present structural errors holding that complete denial of summation amounts to structural error and that existing case law did not clearly establish the restriction of summation as structural error holding that preserved apprendiblakely error like the failure to submit an element to the jury in neder  is not structural error and is instead subject to harmlesserror review