Intentional Conduct and Negligence are not Mutually Exclusive; The Concurrent Cause Doctrine Applies Only When Each Independent Cause Can Injure Without the Other

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…
By: Sheppard Mullin Richter & Hampton LLP