Allstate Insurance Company v. McCarn, 683 N.W.2d 656 arose from the death of sixteen-year-old Kevin LaBelle. Robert McCarn, then sixteen, removed a shotgun that was always stored under a bed. The gun was not normally loaded. Both Robert and Kevin handled the gun. Robert believed it to be unloaded. When Robert was handling the gun, he pointed it at Kevin's face and pulled the trigger. The gun fired, killing Kevin.

Plaintiff and defendants both moved for summary disposition. The trial court granted defendants' motions, holding that the events constituted an "occurrence" within the meaning of the policy. The trial court also held that McCarn's conduct was not intentional or criminal within the meaning of the policy. On appeal, the court concluded that "Robert's intentional actions created a direct risk of harm that precludes coverage." The Michigan Supreme Court reversed that decision, holding that the "accident" was an "occurrence" as defined in the policy thus giving rise to Allstate's potential liability.