BRIDGES V. FARM BUREAU

In an unpublished case decided by the North Carolina Court of Appeals on February 5, 2013, the Court held that a named insured cannot recover under the liability portion of a homeowners policy. In this case, the insured-wife was specifically named on the policy as an insured. The insured-husband allegedly accidentally shot her, and her Estate sought coverage. The insurer relied on an exclusion, which excluded liability for bodily injury to an insured. The court held that the insured-wife was a named insured, and hence she could not recover. The case was slightly more complicated because the couple was separated, but that did not affect the application of this exclusion. The decision of Bridges v. N.C. Farm Bureau illustrates that exclusions are construed narrowly, but nevertheless they will be applied to deny coverage where the exclusion is unambiguous and precludes coverage.