When it comes to liability insurance, the distinction between intentional acts and negligence can have major implications for coverage—especially in cases involving violent conduct. A recent decision from the California Court of Appeal in State Farm Fire and Casualty Company v. Curtis Diblin, et al., 2025 WL 2837668, – – Cal. Rptr. 3d – – (October 7, 2025), underscores how courts analyze the interplay between intentional torts, negligence, and the meaning of “occurrence” under an insurance policy. It also clarifies when the concurrent cause doctrine does — or doesn’t — apply, offering important takeaways for attorneys, insurers, and policyholders alike.
