In New London County Mutual Insurance Company v. Zachem, 145 Conn. App. 160 (2013), the Connecticut Court of Appeals was called upon, as a question of first impression, to decide if coverage existed when vandalism resulted in an explosion and fire that destroyed the property.

The defendants were the owners of real property located on Route 2 in Preston (premises). A single family house and a freestanding garage were located on the premises; the defendants maintained the house as a rental property. The plaintiff issued an insurance policy to the defendants that included coverage for the house and the garage.

The section of the insurance policy entitled ''Perils Insured Against,'' provides in relevant part: ''We insure against risk of direct loss to property described in Coverages A [Dwelling] and B [Other Structures] only if that loss is a physical loss to property.'' Following that provision is a list of exceptions to coverage, which provides in relevant part: ''[W]e do not insure loss . . . caused by . . . vandalism and malicious mischief, theft or attempted theft if the dwelling has been vacant for more than [30] consecutive days immediately before the loss'' (vandalism exception). The policy also contains the following provision related to the list of exceptions to coverage, including the vandalism exception: ''[A]ny ensuing loss to property described in Coverages A and B not excluded or excepted in this policy is covered'' (ensuing loss provision). The policy does not contain definitions for the terms ''vacant'' or ''ensuing loss.''