On January 23, 2017, Noah Ravenscroft killed his wife, Kristy Jo, by stabbing her 24 times, striking her in the chest 13 times. At the time of the homicide, the couple had three minor children. Prior to the homicide, Mr. Ravenscroft had been experiencing auditory hallucinations and paranoid beliefs.
According to a journal kept by Ms. Ravenscroft, and interviews with Mr. Ravenscroft after the homicide, the television would give Mr. Ravenscroft messages that would describe what he was to do. On the night of her death, one of the couple's children overheard Ms. Ravenscroft yelling at Mr. Ravenscroft to get off of her, causing the child to go downstairs and observe Mr. Ravenscroft holding Ms. Ravenscroft down on the couch with his hand over Ms. Ravenscroft's mouth. Ms. Ravenscroft was trying to push Mr. Ravenscroft off of her. Mr. Ravenscroft stood up, retrieved a knife from the kitchen, walked back toward Ms. Ravenscroft, and stabbed Ms. Ravenscroft, killing her. Mr. Ravenscroft had also stabbed himself in the abdomen.
In State Farm Fire & Cas. Ins. Co. v. Noah Ravenscroft, by Conservator Jon Munger, Calvin Morrish Individually and as Personal Representative of the Estate of Kristy Jo L. Ravenscroft, and as Conservator Ian Ravenscroft, Emmalynn Ravenscroft and Ashlea Ravenscroft, and Susan Morrish, No. 345377, State of Michigan Court of Appeals (Sept. 17, 2019), the court was asked to resolve a dispute over insurance coverage by State Farm Fire and Casualty Insurance Company.
Background
On January 25, 2017, Mr. Ravenscroft was released from the hospital and charged with first-degree murder. Following two psychological evaluations for criminal responsibility, Mr. Ravenscroft was found not guilty of first-degree murder by reason of insanity. A wrongful-death action was filed against Mr. Ravenscroft, which included claims from Ms. Ravenscroft's parents, Calvin and Susan.
At the time of Ms. Ravenscroft's death, Mr. Ravenscroft and Ms. Ravenscroft had a homeowners insurance policy issued through State Farm, which defended Mr. Ravenscroft in the wrongful-death action under a reservation of rights. State Farm sought an order that it had no obligation to defend or indemnify Mr. Ravenscroft under the terms of the homeowners policy because the bodily injury to Ms. Ravenscroft did not constitute an "occurrence," and even if it did constitute an "occurrence," coverage was precluded because the homeowners policy excluded coverage for bodily injury, which is expected or intended by the insured.
Calvin and Susan Ravenscroft contended that, on the basis of Mr. Ravenscroft's psychiatric evaluations and the record in the criminal case, Mr. Ravenscroft 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. They then contended that Mr. Ravenscroft was incapable of forming the requisite intent to end Ms. Ravenscroft's life, making his actions an accidental or negligent occurrence.
The trial court concluded that, given the record, the insured was indeed unable to form the required intent.
Analysis
An insurance policy must be enforced in accordance with its terms. If not defined in the policy, however, courts will interpret the terms of the policy in accordance with their commonly used meaning. Courts should not create ambiguity where the terms of the contract are clear. Where there is no ambiguity, the court will enforce the terms of the contract as written.
Under the terms of the homeowners policy, liability coverage exists when there is an "occurrence." "[O]ccurrence,' … means an accident.…"
The homeowners policy did not define an "accident." However, in cases similar to this one, "where the respective policies define an occurrence as an accident, without defining an accident," the Michigan Supreme Court has repeatedly stated that an accident is an undesigned contingency, a casualty, a happening by chance, something out of the usual course of things, unusual, fortuitous, not anticipated, and not naturally to be expected. Accidents are evaluated from the standpoint of the insured, not the injured party. (Auto Club Group Ins Co v Marzonie, 447 Mich. 624, 648; 527 N.W.2d 760 [1994].) The appropriate focus of the term "accident" must be on both the injury-causing act or event and its relation to the resulting property damage or personal injury. If both the act and the consequences were intended by the insured, the act does not constitute an accident. On the other hand, if the act was intended by the insured, but the consequences were not, the act does constitute an accident unless the intended act created a direct risk of harm from which the consequences should reasonably have been expected by the insured.
As to the perspective from which the analysis should be made, the question is not whether a reasonable person would have expected the consequences, but whether the insured reasonably should have expected the consequences.
There is no dispute that Mr. Ravenscroft had a mental illness at the time he killed Ms. Ravenscroft. State Farm argued that Mr. Ravenscroft's conduct in holding Ms. Ravenscroft down, retrieving a knife, and stabbing her 24 times while she screamed revealed his clear intent to kill her. Further, State Farm argued that Mr. Ravenscroft's declarations to the police that he had killed Ms. Ravenscroft, as well as his comments during his psychological evaluation for criminal responsibility as to his thoughts and actions in stabbing Ms. Ravenscroft to death, revealed his intent to kill her.
The record makes clear that the death of Ms. Ravenscroft was not the result of an accident or that the harm inflicted was not intended. Nowhere in this record could the court glean any evidence that could lead it to conclude that Mr. Ravenscroft accidentally stabbed his wife 24 times, 13 of which were to her chest. Focusing on both the injury-causing act or event and its relation to the resulting personal injury, the court of appeal concluded that the bodily injury to Ms. Ravenscroft was not an "occurrence" under the terms of the policy issued by State Farm, and State Farm was, therefore, under no legal obligation to defend or indemnify Mr. Ravenscroft because no coverage existed under the homeowners policy, and summary disposition should be entered for plaintiff on that basis.
Even an insane or mentally ill person can intend or expect the results of his actions within the meaning of an insurance policy's exclusionary clause. It is inappropriate to conclude that someone found not criminally liable by reason of insanity cannot be found to have intended his actions and to have expected their consequences.
The record reveals that, in addition to other facts, Mr. Ravenscroft was diagnosed with bipolar disorder, opiate dependence, and nicotine dependence. In addition, subsequent records stated that Mr. Ravenscroft was in imminent danger to self—secondary to mental incapacity, not able to take care of self, not able to understand treatment needs, severe neuro-vegetative symptoms, no social support, and was a danger to himself and others.
When the police arrived at the home after Ms. Ravenscroft was killed, Mr. Ravenscroft told the police that he had killed Ms. Ravenscroft and asked the police to shoot him. The evidence establishes that Mr. Ravenscroft was undoubtedly suffering from a mental illness.
In conclusion, "despite the fact that Noah, for purposes of criminal liability, was incapable of understanding the legal ramifications of his actions, the evidence supports the conclusion that he intended to kill Kristy Jo. Kristy Jo's death was the result of Noah's intent to take a knife and kill Kristy Jo, despite the fact that Noah was delusional. Accordingly, the exclusionary clause of the homeowners policy applied and there was no coverage."
Conclusion
Liability insurance only applies to a contingent or unknown event causing injury to a third person. The sanity of the person causing the injury is irrelevant. Clearly, the actions of Mr. Ravenscroft revealed that the death of Ms. Ravenscroft was not contingent but was intended by Mr. Ravenscroft. He couldn't form the intent needed to be convicted of a crime, but he knew that he worked to kill Ms. Ravenscroft and admitted to the act.
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