Alm v. Hartford Fire Ins. Co – Case Brief Summary (Wyoming)

In Alm v. Hartford Fire Ins. Co., 369 P.2d 216, 217 (Wyo. 1962), the Court adopted, with approval, this language from Ritchie v. Anchor Cas. Co., 135 Cal. App. 2d 245, 286 P.2d 1000, 1006 (1955):

"If the complaint filed against the insured alleges several causes of action, some of which are not covered by the policy but one or more is within its terms, the insurer is bound to defend the action."

The Court went on to point out that even if doubt exists with respect to the duty to defend, it should be resolved in favor of the insured. The duty to defend, therefore, extends to the entire suit brought against the insured. Even though the duty to defend is present, it does not require payment of a judgment based on claims other than those covered by the policy.