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A Court of Appeals in Ohio addressed the issue of whether an insurer had a duty to defend and indemnify the insured after the insured pled to complicity to engage in arson. This case is Black v. Richards, 2010 WL 2546705 (Ohio App. 5 Dist.).

Hillyard and Richards went to property owned by Black and entered through a hole in the bottom of a rear wooden door. While in the house, Richards set fire to curtains at the bottom of a landing. After Hillyard pulled the curtains down, causing them to fall partly on a box, the two attempted to stomp the fire out, but the fire spread to three adjoining buildings. Richards and Hillyard entered a plea of admission to a charge of complicity to engage in arson and were adjudged delinquent by the county juvenile court.

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