A Massachusetts appeals court held that a fraternity officer was not an insured under CGL and catastrophe policies because his actions fell outside of his fraternity duties and constituted hazing in Royal Surplus Lines Ins. Co. v. Cotton States Mut. Ins. Co., No. 05-P-1035, 2006 WL 2422769 (Mass. App. Ct. Aug. 22, 2006) (unpublished).

Scott Krueger died during a pledge initiation event sponsored by the Phi Gamma Delta fraternity at the Massachusetts Institute of Technology. The event, called Animal House Night, involved watching the movie Animal House and consuming a certain amount of alcoholic beverages. Fraternity members also presented each pledge with a bottle of an alcoholic beverage.