Ruling against the Roman Catholic Diocese of Brooklyn, New York's Court of Appeal held that a priest's alleged acts of sexual molestation "that spanned a six-year period and transpired in multiple locations," did not constitute "a continuous or repeated exposure to substantially the same general harmful conditions," but rather, multiple occurrences subject to separate self-insured retentions under the Diocese's liability insurance policies. Roman Catholic Diocese of Brooklyn v. Nat'l Union Fire Ins. Co. of Pittsburgh, P.A., 87 A.D.3d 1057 (N.Y. May 7, 2013). The Diocese was seeking to avoid seeing the bulk of its coverage claims for a $2 million settlement consumed by the application of seven distinct self-insured retentions of $250,000. Unlike most other jurisdictions, the New York court applied neither the "cause" test, which determines the number of covered occurrences by determining whether damage resulted from a single proximate cause of loss, nor the minority "effects" test, which determines the number of occurrences by counting the number of persons harmed. Instead, the court declared that New York courts must apply the "unfortunate event test," which considers "whether there is a close temporal or spatial relationship between the incidents giving rise to injury or loss, and whether the incidents can be viewed as part of the same causal continuum, without intervening agents or factors." Here, the court concluded, sexual abuse that occurred in multiple locations over multiple policy periods "lack[ed] the requisite temporal and spatial closeness to join the incidents."