The doctrine of inferred intent applies where an insured's intentional act of setting fire is intrinsically tied to the resulting harm.

The insured-plaintiff admittedly set fire to the comforter in her master bedroom in an attempt to have her husband become a hero by extinguishing the flame. The insureds were unable to extinguish the flame, and the fire destroyed their home and caused damage to the exterior of their neighbor's dwelling. Farmers Insurance denied coverage because the fire was intentionally set by a named insured. The intentional acts exclusion states, "If any insured directly causes or arranges for a loss to covered property in order to obtain inurance benefits, this policy is void. We will not pay you or any other insured for this loss." The court found that the doctrine of inferred intent applied because the insured's act of setting the fire was intrinsically tied to the harm that resulted and the language of the intentional act exclusion in the policy did not warrant a different result.

Case Law Alert - 2nd Qtr 2012