The North Carolina Court of Appeals held that intentional acts of minors causing property damage preclude coverage for claims of negligent supervision asserted against the minors’ parents. Plum Properties, LLC v. N. Carolina Farm Bureau Mut. Ins. Co., Inc., 802 S.E.2d 173, 177 (N.C. Ct. App. 2017).

Minors vandalized a number of homes, and the owners made claims against the minors and against the parents of the minors for negligent supervision. The parents had homeowners’ policies that included as insureds relatives of the named insureds but contained an exclusion of coverage for intentional injury or damage. The trial court granted summary judgment for the insurer, finding coverage for all damages excluded due to the exclusion.

The North Carolina Court of Appeals affirmed, rejecting the argument that because the parents were only alleged to be negligent in the supervision of their children, the vandalism constituted an “occurrence” as applied to the parents. The court concluded that because the minors both intended to inflict property damage and qualified as insureds, coverage for all claims stemming from the vandalism were excluded, including the claims for negligent supervision against the parents.