A

It has always been the FC&S opinion that if an exclusion uses the phrase “any insured”, then that exclusion applies to every insured. Using your example, if any of the multiple insureds under one of your client's CGL policy uses an auto and causes an accident, the client's CGL policy will not respond to a claim made against the client. This opinion is based on many court decisions that have tackled that very issue. Of course, there are other decisions that support the idea that the words “any insured” in an exclusion only apply to a single insured and that other insureds have to be treated separately, especially if the policy has a separation of insureds clause. There is an excellent case, decided recently, that discusses the issue and lists court decisions on both sides. The case is West American Insurance Company v. AV&S, Incorporated, 145 F3d 1224 (1998). This particular case goes against our opinion on the matter, but it does offer solid information for those who are interested in both sides of the question. Subscribers might also want to read the FC&S article that discusses the subject; see Separation of Insureds. For print subscribers, this article is on the Notes CGL M- pages.