Liberty Surplus Insurance Corporation, Plaintiffs and Respondents v. Ledesma & Meyer Construction Company…

Summary

The court held that an employer's commercial general liability policy may cover a negligent hiring, retention, or supervision claim even when the employee intentionally injured the third party. The employee's intentional misconduct does not eliminate the potential for coverage because the employer's alleged negligence is an independent tort and may constitute an accidental occurrence from the employer's perspective. The court further held that causation must be assessed under tort principles, including whether the employer's negligence was a substantial factor in causing the injury.