On October 19, 2016, the California Supreme Court granted the United States Ninth Circuit Court of Appeals' request for the Supreme Court to decide a question of California law presented in the lawsuit entitled: Liberty Surplus Insurance v. Ledesma and Meyer Construction. The question presented relates to whether claims for negligent supervision based on the intentional conduct of an employee relating to sexual molestation constitute a potential "accident" as required by the definition of occurrence in general liability policies.

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