In Century Transit Systems, Inc. v. American Empire Surplus,(1996) 42 Cal.App.4th 121, a taxicab company's insurer refused to defend against an action in which an employee attacked and battered two participants in a demonstration. The complaint against the employer alleged assault and battery and negligent hiring. The employer argued that the intentional act exclusion in the policy did not preclude coverage for the negligent hiring claim. ( Id. at pp. 123-124, 126-127.) The court disagreed, stating that the exclusion precluded coverage for assault and battery, despite multiple legal theories advanced against the insured. ( Id. at p. 127.) "Therefore, liability for negligent hiring was wholly dependent upon an injury caused by excluded event and was not a true 'independent' cause of the plaintiff's injury." ( Id. at pp. 128-129, fn. 6.)