Public policy does not allow insurance against the results of intentional acts. Thus, most liability insurance contracts contain a clause that excludes coverage for bodily injury or property damage intended or expected as a result of an insured's actions These clauses are generally referred to as "intentional acts exclusion clauses" or "intentional injury exclusion clauses." The real question in all cases is what the insurer must show to invoke the exclusion. There are two basic requirements: (1) The act done was intended; and (2) there was some intent for the act to cause injury. Most courts agree that the act must have been intentional from the standpoint of the insured. Courts are split, however, on the question of the level of intent that must be shown regarding the injury that results from the act. There are three general approaches to this issue.
James E. Berger,
Liability Insurers Get a Fair Deal,
59 Mo. L. Rev.
Available at: https://scholarship.law.missouri.edu/mlr/vol59/iss1/14