California Court Clarifies "Occurrence" Definition in Homeowners Insurance Intentional Acts Case
The California Fourth District Court of Appeal issued a significant ruling on October 7, 2025, in the case State Farm Fire and Casualty Company v. Diblin, clarifying the definition of "occurrence" within homeowners insurance policies when intentional acts and negligence claims are involved.
The case stems from Curtis Diblin's assault on his housemate Monee Gagliardo in San Diego County, where he caused serious bodily injury with a rubber mallet, leading to both criminal and civil actions. Gagliardo’s civil complaint included negligence and various intentional tort causes, such as gender violence and civil rights violations. Diblin’s homeowners insurance with State Farm included personal liability coverage limited to damages caused by an "occurrence," defined as an accident resulting in bodily injury, and specifically excluded coverage for injuries resulting from intentional acts by the insured.
The jury found Diblin liable for both gender violence and negligence, awarding compensatory damages and, initially, punitive damages, the latter later waived. State Farm continued defense under reservation of rights but sought a declaratory relief action prior to judgment asserting no obligation to cover the damages due to intentional act exclusions in the policy. The lower trial court ruled in favor of State Farm, determining no coverage existed because the injuries were not caused by an "occurrence" but were the result of deliberate, intentional actions, which was upheld on appeal. The court found that despite the jury's findings of negligence, these did not contradict the finding of intentional conduct, as the negligence definition could encompass intentionally harmful acts. The appellate court also rejected the "concurrent independent cause" argument, concluding the intentional and negligent acts were not independent but intertwined, thus negating coverage. Further, the court declined to require a new jury to assess whether Diblin had a "preconceived design to injure" under California Insurance Code Section 533, affirming that the jury's verdict already supported the absence of coverage based on intentional act exclusions. This ruling emphasizes that injuries stemming from intentional acts by an insured do not constitute a covered "accident" or "occurrence" under standard homeowners liability policies, even when negligence claims are also present.
It reinforces insurers’ rights to deny coverage for damages arising from intentional conduct, shaping claims handling and litigation strategy in civil assault cases linked to homeowners insurance. Legal practitioners in insurance coverage and bad faith litigation should note the clarification of these definitions and exclusions in California jurisdiction, potentially influencing case outcomes and insurer liabilities.