Minor's Alcohol-Related Death Foreseeable: No "Occurrence" Within the Meaning of a Homeowner's Policy Court of Appeals of Ohio

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Court of Appeals of Ohio   

In Sheely v. Sheely, 2012 WL 34451 (Ohio Ct. App. Jan. 9, 2012), the Court of Appeals of Ohio held that a 16-year-old girl's death caused by alcohol that had been provided by her father did not qualify as an "occurrence" within the meaning of a homeowner's policy, precluding coverage.

On May 13, 2007, Ivy Sheely died of alcohol-induced asphyxiation after she drank almost an entire bottle of vodka that she brought to a friend's party.  Ivy's father, Dan Sheely, had purchased the vodka earlier that day, although accounts differed as to whether Dan purchased it specifically for Ivy or simply as part of his "house supply."  Dan admitted that he generally permitted Ivy and her friends to drink alcohol in his house, but claimed he did not know that Ivy had taken the vodka to her friend's party the night that she died.

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