Allstate Ins. Co. v. Peasley

In Allstate Ins. Co. v. Peasley, 131 Wn.2d 420, 932 P.2d 1244 (1997), a criminal act exclusion clause in a homeowners' insurance policy precluded coverage for injuries sustained by a guest who was shot by the homeowner. Peasley, 131 Wn.2d at 423. The Court rejected the guest's argument that such a clause violated public policy. Rather than forcing the insurance company to indemnify the homeowner for his criminal act, we enforced the exclusion clause. Peasley lends support for the proposition that, in general, insurers need not provide coverage for losses caused by the criminal acts of their insureds. The Court declined to apply the public policy of compensating innocent victims asserting that this policy does not apply outside the context of automobile insurance. "'We do not perceive the same level of concern for financial compensation by negligent homeowners as exists for negligent automobile owners and users.'" Id. at 432.