Fire Ins. Exchange v. Altieri

In Fire Ins. Exchange v. Altieri (1991) 235 Cal. App. 3d 1352, the Court of Appeal held that an exclusion in a homeowner's policy for injuries caused by the intentional acts of "an insured" unambiguously barred coverage for claims against the parents arising from injuries sustained in a fight involving their minor son. ( Id. at pp. 1360-1361.) The court specifically distinguished exclusions based on the conduct of "the insured" from those in which conduct by "an insured" or "any insured" triggered the exclusions. (Ibid.) It found the latter phrases were unambiguous in excluding coverage for each and every person insured under the policy based on the intentional wrongdoing of a single insured. (Ibid.)