In Salem Group v. Oliver, 128 N.J. 1, 607 A.2d 138 (1992), a divided Court held that a homeowners insurer owed a duty to defend against a social host claim where a vehicle accident gave rise to the underlying personal injury suit, despite an automobile exclusion in the homeowner's policy. The homeowner had served alcohol to his nephew who thereafter drove an all-terrain vehicle (ATV) and had an off-premises accident. The homeowners policy had an exclusion for injuries arising out of the operation, ownership or use of a motor vehicle. In the context of the duty to defend, the Court looked to the allegations in the complaint as to the insured social host's involvement and thought the excluded risk (the use of the vehicle) was merely "an additional cause of the injury." Salem Group, supra, 128 N.J. at 3, 607 A.2d 138. In resolving whether the homeowners insurer should defend in light of the social host allegations, the Court adopted the rule that "when two . . . risks constitute concurrent proximate causes of an accident, the insurer is liable to defend so long as one of the causes is covered by the policy." Id. at 5-6, 607 A.2d 138.