United States Fidelity & Guaranty Co. v. Lightning Rod Mutual Insurance

I concur in the majority’s resolution of this case, and join in reversing the judgment of the court of appeals and reinstating the judgment of the trial court on the certified issue. I write separately to underscore the ambiguity of the “for a fee” exclusion.

A special category of cases has emerged to cover the general fact pattern presented by this case. These cases could be labeled “pizza delivery cases,” although the basic issue could arise in any case which involves a similar delivery of a product by an employee. Courts in various states have found the same or *587like exclusions unenforceable…