Ohio Supreme Court - Insurance for Multiple Stabbing:

A policy that excludes coverage for injuries that arise out of the intentional or criminal acts of "any" insured, does NOT exclude coverage for claims of negligent entrustment or supervision brought against "any" other insured.

SAFECO INSURANCE COMPANY OF AMERICA, APPELLANT, v. WHITE ET AL.; FEDERAL INSURANCE COMPANY ET AL. Ohio Supreme Court, Decided August 4, 2009.

SUMMARY:
The Ohio Supreme Court has now held that when one insured commits an intentional act (in this case the multiple stabbing of a young girl), the homeowner insurance policy must still provide coverage for any claims that other insureds were negligent in supervising or entrusting the insured perpetrator. This is despite any exclusion that precludes coverage for bodily injury that arises out of the conduct of "any insured."

Specifically, the Court held:

1. When a liability insurance policy defines an "occurrence" as an "accident," a negligent act committed by an insured that is predicated on the commission of an intentional tort by another person, e.g., negligent hiring or negligent supervision, qualifies as an "occurrence."

2. Insurance-policy exclusions that preclude coverage for injuries expected or intended by an insured, or injuries arising out of or caused by an insured's intentional or illegal acts, do not preclude coverage for the negligent actions of other insureds under the same policy that are predicated on the commission of those intentional or illegal acts, e.g., negligent hiring or negligent supervision.