Concurrent Cause Doctrine
The concurrent cause doctrine holds that if more than one cause concurred to cause a loss, one of which is excluded and the other not, the entire loss is covered. It was finalized by the California Supreme Court in State Farm Mutual Auto Ins. Co. v. Partridge, 10 Cal. 3d 94, 109 Cal. Rptr. 811 (1973). In this case, the court found that coverage existed for defense and indemnity under a homeowners policy, even though the accident occurred while the insured was operating an automobile (excluded by the homeowners policy), because there was a nonexcluded event that concurred to cause the loss. The facts of the Partridge case illustrate how the concurrent cause doctrine was born out of an outrageous fact situation and the potentiality doctrine.
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