In 2015, Continental Casualty Company issued a commercial general liability policy to Zongwei Shen dba Nobles Massage Spa. The policy covered Shen (the spa owner) and Zhong Xin (the spa manager and Shen’s wife) for damages because of bodily injury that occurred during the policy period. The policy contained an abuse or molestation exclusion that excluded coverage for bodily injury “arising out of” (a) the “actual or threatened abuse or molestation by anyone of any person while in the care, custody or control of any insured,” or (b) the negligent employment, supervision, or retention “of a person for whom any insured is or ever was legally responsible and whose conduct would be excluded by (a).”Continue Reading The California Court of Appeal Interprets the Meaning of “Care, Custody, or Control” in the Context of an Abuse or Molestation Exclusion