Following two psychological evaluations for criminal responsibility, he was found not guilty of first-degree murder by reason of insanity.

Ravenscroft's wife's parents (together, the "Parents") filed a wrongful death action against him.

Ravenscroft's homeowner's insurance carrier, State Farm Fire and Casualty Insurance Company, defending him in the Parents' wrongful death action under a reservation of rights.

State Farm also asked a Michigan court to declare that it was not obligated to defend or indemnify Ravenscroft because the bodily injury to his wife did not constitute an "occurrence" and even if it did constitute an "occurrence," coverage was precluded because the State Farm policy excluded coverage for bodily injury expected or intended by the insured.

The trial court entered a stipulated order that stated that, following the exhaustion of all appellate remedies, if it was determined that the alleged bodily injury was caused by an occurrence and the alleged bodily injury was not expected, intended, or the result of Ravenscroft's willful or malicious actions, then State Farm would pay the Parents the policy limit of $500,000. The parties also agreed that Ravenscroft met the statutory criteria for mental illness and legal insanity.

The Parents moved for summary disposition, contending that, on the basis of Ravenscroft's psychiatric evaluations and the record in the criminal case, he lacked the substantial capacity to appreciate the nature and quality or wrongfulness of his conduct or to conform his conduct to the requirements of the law and, therefore, that he was incapable of forming the requisite intent to end his wife's life, making his actions an accidental or negligent occurrence.

The trial court granted summary disposition against State Farm, and the insurer appealed.

The Michigan Appellate Court's Decision

The appellate court reversed.

In its decision, the appellate court first ruled that Ravenscroft's wife's death "was not the result of an accident," finding that he had not "accidentally" stabbed her 24 times. The appellate court decided that Ravenscroft clearly "intended the harm that was inflicted" and, therefore, the bodily injury to his wife was not an "occurrence" under the State Farm policy.

The appellate court added that, even if Ravenscroft's wife's death was an occurrence under the State Farm policy, the policy excluded coverage for bodily injury "either expected or intended by the insured[.]" It then ruled that although Ravenscroft "was undoubtedly suffering from a mental illness," and despite the fact that he was incapable of understanding the legal ramifications of his actions for purposes of criminal liability, the evidence supported the conclusion "that he intended to kill" his wife.

The appellate court added that although Ravenscroft "may not have been criminally liable for his acts, he was capable of foreseeing their consequences and understanding what he was doing, i.e., intentionally killing [his wife]."

The appellate court observed that this was "not a situation" where Ravenscroft "mistook the knife for some other object" or where he could not distinguish right from wrong. It pointed out that, when police arrived at the scene, Ravenscroft told them that he had killed his wife.

The appellate court said that it could not find that her death was the result of an accident and there was "no other conclusion but that [he] intended to take a knife and kill [his wife], despite the fact that [he] was delusional." Accordingly, it concluded, the exclusionary clause of the State Farm policy also applied, and there was no coverage.

The case is State Farm Fire & Casualty Ins. Co. v. Ravenscroft, No. 345377 (Mich. Ct. App. Sept. 17, 2019).