State Farm Fire And Casualty Company v. Nickolas Peters
75705-9
| Wash. Ct. App. | Aug 14, 2017Background
- Reeve Belt intentionally formed a fist and struck Nikolas Peters multiple times in the face, fracturing Peters’ jaw in three places; Belt pleaded guilty to fourth-degree assault.
- Belt was covered under his parents’ State Farm homeowner’s policy, which provided liability coverage for bodily injury caused by an "occurrence," defined as "an accident," but the policy did not expressly define "accident."
- The policy excluded bodily injury "which is either expected or intended by the insured" and injuries resulting from willful and malicious acts.
- State Farm defended under a reservation of rights and filed a declaratory judgment action seeking a ruling that it owed no duty to defend or indemnify Belt; the trial court granted summary judgment for State Farm.
- In opposition, Peters submitted a declaration from Belt admitting he hit Peters but stating he did not expect or intend to injure him; Peters argued this created a factual dispute about whether the act was an "accident."
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Belt's intentional punching can be an "accident" under the policy | Peters: Belt's declaration that he did not intend injury creates a factual dispute whether the result was accidental | State Farm: Policy lacks an "accident" definition, so common-law objective standard applies; intentional punching producing foreseeable harm is excluded | Court: Affirmed summary judgment for State Farm — objective reasonably foreseeable standard bars coverage for intentional acts that foreseeably cause injury |
| Whether an express definition of "accident" should be inferred from policy text | Peters: Exclusion language and formatting imply an "accident" definition should be read into the policy | State Farm: No express definition appears; cannot infer a definition from exclusions; use common law | Court: Declined to infer definition; applied common-law definition |
| Whether subjective lack of intent to injure raises triable issue | Peters: Belt's subjective statement that he did not expect injury creates a material factual dispute | State Farm: Subjective belief is irrelevant where an objective prudent-person would foresee the harm | Court: Rejected subjective-intent argument; objective foreseeability controls |
| Whether record was insufficiently developed for summary judgment | Peters: Trial court erred by granting summary judgment without more discovery | State Farm: Police report and admissions suffice; Peters had opportunity to develop record | Court: Record adequate; Peters failed to create genuine issue of material fact |
Key Cases Cited
- State Farm Fire & Cas. Co. v. Ham & Rye, L.L.C., 142 Wn. App. 6 (contemporary common‑law articulation: intentional act is not an "accident" if harm was reasonably foreseeable)
- Detweiler v. J.C. Penney Cas. Ins. Co., 110 Wn.2d 99 (confusion of events can create triable issue on foreseeability)
- Safeco Ins. Co. of Am. v. Butler, 118 Wn.2d 383 (foreseeability of ricocheted bullet precluded accident coverage)
- Queen City Farms, Inc. v. Cent. Nat’l Ins. Co. of Omaha, 126 Wn.2d 50 (subjective expectations considered in toxic‑tort CGL context; distinguished here)
- Getz v. Progressive Specialty Ins. Co., 106 Wn. App. 184 (policy text ambiguities and formatting cannot be invoked to change defined/undefined term meanings)