In Rena, Inc. v. Brien, 310 N.J. Super. 304, 708 A.2d 747 (App.Div.1998), the policy insured the tenants and landlord of a building against fire loss. The tenants arranged for the building to be burned so that they could obtain the insurance proceeds. In considering the innocent landlord's claim under the policy, the court addressed the differing effect of exclusions that refer to acts of "the insured" and those that refer to acts of "an insured." The court denied coverage to the innocent insured, finding no ambiguity in an insurance policy that excluded coverage for damage resulting from "'any fraudulent, dishonest or criminal act done by or at the instigation of any insured. . . .'" Id. at 309, 708 A.2d 747. As reflected in the opinion, which thoroughly canvasses the relevant cases throughout the United States and the insurance texts, the phrases "any insured" and "an insured," in coverage exclusions have been interpreted almost uniformly, absent contrary statutory authority, as requiring the denial of policy benefits to innocent insureds. Id. at 321-25, 708 A.2d 747. If an unambiguous policy exclusion is enforceable against an innocent party, a fortiori it must be enforceable against an insured whose liability, as here, depends on fault. Cf. id. at 325, 708 A.2d 747.