In Allstate Ins. Co. v. Raynor, 93 Wn. App. 484, 969 P.2d 510, review granted, 139 Wn.2d 1001, 989 P.2d 1136 (1999), a homeowner shot and killed a neighbor woman and her child. Raynor, 93 Wn. App. at 490. The homeowner argued his homeowners' insurance policy covered any liability arising from the incident.
The Court of Appeals held the exclusion clause applied, noting the policy's language was clear, and an average purchaser of insurance would understand the homeowner's actions would be excluded criminal acts. Raynor, 93 Wn. App. at 495.