Courts like those in Florida that apply the four corners rule of insurance contract interpretation of the duty to defend allow a plaintiff's lawyer to skillfully draw a complaint that will require the defendant's insurer to defend even when it is clear from existing evidence that there is no coverage.
It is time that the four corners rule, or the eight corners rule, where the court only reads the complaint and the policy to determine coverage, be removed from any appellate jurisprudence.
The Four Corners Rule, applied in Pennsylvania and several other states, limits the decision to defend and/or indemnify an insured to a review of the allegations of a complaint.
The four corners rule worked an injustice in this case.