In Gray v. Zurich Insurance Co. (1966) 65 Cal.2d 263, the insured had a "comprehensive" liability policy providing coverage for "'all sums which the insured shall become legally obligated to pay as damages because of bodily injury or property damage,'" but excluding "'bodily injury . . . caused intentionally by or at the direction of the insured.'" (Id. at p. 267.) The insured was involved in an altercation with another driver: after a near-collision, the other driver "left his vehicle, approached insured's car in a menacing manner and jerked open the door. At that point insured, fearing physical harm to himself and his passengers, rose from his seat and struck the other driver." (Id. at p. 267, fn. 1.) The other driver sued the insured for intentional tort; the insured, whose insurer refused to provide a defense, claimed self-defense but ultimately was found liable by a jury for $ 6,000 in actual damages. (Id. at p. 267.) In a subsequent action by the insured against his insurer, the Gray court found ambiguity and uncertainty in the policy, and held the insured could reasonably expect a defense under the circumstances. (Gray, supra, 65 Cal.2d at pp. 272-273.) Of particular note, the court explained: "Despite the other driver's pleading of intentional and willful conduct, he could have amended his complaint to allege merely negligent conduct. Further, insured might have been able to show that in physically defending himself, even if he exceeded the reasonable bounds of self-defense, he did not commit willful and intended injury, but engaged only in nonintentional tortious conduct. Thus, even accepting the insurer's premise that it had no obligation to defend actions seeking damages not within the indemnification coverage, we find, upon proper measurement of the third party action against the insurer's liability to indemnify, it should have defended because the loss could have fallen within that liability." (Id. at p. 277)