The insurer filed for a declaratory judgment as to whether the general liability policy covered negligence claims by a customer who was shot at the insured's premises. The policy contained a firearms exclusion. This case is Capitol Specialty Insurance v. JBC Entertainment Holdings, Inc., 2012 WL 6098259.

 JBC Entertainment operates a nightclub in Seattle. The general liability policy it purchased from Capitol Specialty Insurance contained a firearms exclusion that prevented coverage for bodily injury or property damage that arises out of, related to, is based upon, or is attributable to the use of a firearm.

 On March 21, 2010, an unknown person fired a gun at the nightclub, injuring Mika. To recover damages related to the shooting, Mika filed a complaint against JBC and others. Mika asserted that JBC should have provided enhanced security and claimed negligent hiring, training and supervision, and negligent failure to provide adequate security. All the claims related to the shooting itself. JBC tendered the lawsuit to Capitol which filed a declaratory judgment action based on the firearms exclusion to determine whether the policy applied. The trial court ruled in favor of the insurer and the insured appealed.