The Second Appellate District reversed a judgment. The court held that an unintended outcome did not transform a deliberate act into an “accident” for purposes of insurance coverage.
Patrick Frake was intoxicated and engaging in routine horseplay when he struck his friend John King in the groin. The blow resulted in significant and unexpected injuries. King sued Frake. Frake tendered defense of the action to State Farm General Insurance Company under a renter’s policy that provided coverage for bodily injury “caused by an occurrence,” which the policy defined as “an accident.” State Farm defended the action under a reservation of rights.
