State Farm has secured a key appellate win in California, confirming insurers aren’t liable for intentional assault claims under standard homeowners’ policies.
On October 7, 2025, the California Court of Appeal, Fourth Appellate District, Division One, affirmed a judgment in favor of State Farm Fire and Casualty Company, holding that the insurer was not required to indemnify its policyholder, Curtis Diblin, for a $2.5 million judgment after Diblin was found liable for assaulting his housemate, Monee Gagliardo.
The dispute arose from a May 2015 incident in which Diblin struck Gagliardo multiple times on the head with a mallet while they were living together. Gagliardo sued Diblin in civil court and was awarded more than $2.5 million in compensatory damages after a jury found in her favor on claims of gender violence and negligence.
Before the judgment in the civil case was finalized, State Farm filed a separate lawsuit seeking a declaration that it had no duty to pay the damages under Diblin’s homeowner’s policy. State Farm’s position was that its policy only covered injuries resulting from an “occurrence,” defined as an “accident,” and that the policy specifically excluded coverage for injuries that were “expected or intended by the insured” or resulted from “willful and malicious acts.”
Diblin and Gagliardo argued that the jury’s finding of negligence should trigger coverage, since negligence is typically associated with accidental conduct. However, the courts determined that all of Gagliardo’s claims, including negligence, were based on the same intentional assaultive conduct. The jury also found that Diblin acted with malice and oppression, which the court noted was inconsistent with accidental injury.
The appellate court agreed with the trial court’s interpretation, holding that the policy’s coverage for “accidents” did not extend to deliberate acts of violence, even if a negligence claim was also found. The court also pointed to the policy’s exclusion for intentional acts and California Insurance Code section 533, which bars coverage for willful acts, as further support for denying coverage.
As a result, the court affirmed that State Farm owed no duty to indemnify Diblin for the damages awarded to Gagliardo, as the injuries did not arise from an “accident” and were excluded by the policy’s intentional acts provision.
The October 7, 2025, decision clarifies the limits of liability coverage under homeowner’s policies in California, particularly in cases involving intentional conduct, and highlights the importance of policy language and exclusions for insurers and policyholders alike.
