Coverage for heroin dealers found to be against public policy
In 1998, a young woman in Pennsylvania went to a man's home one evening, hoping to obtain heroin. At the time of the visit, the man was said to have been drinking beer and was under the influence of marijuana and heroin. The next day, the woman was found dead in the man's home.

The young woman's parents filed wrongful death and survival actions against the man. They alleged: (1) that the man had sold heroin to the young woman; (2) that he knew of, or should have foreseen, the harmful and dangerous consequences of selling it to her; (3) that he made no attempt to check on her condition during the evening and the following morning; and (4) that he made no attempt to revive her, instead leaving her to go to work.

The man's homeowners insurer filed for a declaratory judgment, alleging its coverage wasn't triggered by the events and it didn't have a duty to defend or indemnify. The policy provided coverage for an "occurrence," defined as an "accident," but excluded coverage for bodily injury that was expected or intended by the insured.