On December 30, 2010, the Ohio Supreme Court issued a
significant decision which clarified the ever-changing law on
coverage for intentional acts. In a key part of the ruling, the
Court emphasized the importance of the doctrine of inferred intent,
defining when it should apply to preclude coverage. Commenting on
prior key cases, the Court explained that the doctrine is not
limited to cases of sexual molestation or homicide. Rather, it can
be applied whenever the insured's intentional act and the harm
caused by that act are intrinsically tied so that the act has
necessarily caused the harm.
The strange facts involve an ill-fated teenage prank. A group of
teenagers positioned a lightweight Styrofoam target deer, fastened
to a piece of wood so that it could stand upright, just below the
crest of a hill on a hilly and curvy two-lane, 55-mile-per-hour
road. The teens placed the target on the road after dark in a
position where drivers could not see it until they were 15 to
