State Farm Fire And Casualty Company v. Curtis Diblin

(December 2025) - In State Farm Fire and Cas. Co. v. Diblin, 114 Cal.App.5th 1245 ( October 7, 2025), the Fourth District Court of Appeal affirmed the trial court's entry of judgment finding that indemnity coverage was not afforded under the State Farm Fire and Casualty Company ("State Farm") policy issued to insured, Curtis Diblin ("Diblin") for a judgment rendered in an underlying lawsuit based on Diblin striking plaintiff Monee Gagliardo ("Gagliardo") with a rubber mallet three times from behind. State Farm defended Diblin against the underlying Gagliardo lawsuit, but secured a judgment in a declaratory relief action arguing that Diblin acted intentionally rather than by accident, such that coverage was not afforded by the policy for the $2.5 million judgment entered against Diblin. State Farm relied on the following evidence in arguing that Diblin's conduct did not constitute an "occurrence" as defined in the State Farm policy: