the Court of Appeals interpreted an assault and battery exclusion in a case stemming from an assault in a nightclub. There, club staff allowed persons previously removed from the club due to an altercation to reenter the club. Id. at 108. The two involved in the previous altercation again confronted one another and patrons “informed [club] security personnel of the ensuing melee, but they failed to take any action.” Id. Interpreting the language of the policy, the Court of Appeals held that the insurer had no duty to defend because the negligence claim by the injured patron fell within the “based on assault and/or battery” exception. Id. at 109, 111. Numerous other cases have similar holdings. See, e.g., Detweiler v. J.C. Penney Cas. Ins. Co., 110 Wn.2d 99, 109, 751 P.2d 282 (1988) (<HOLDING>); Krempl v. Unigard Sec. Ins. Co., 69 Wn. App.
holding that  1109a requires causal connection between breach and loss holding that there must be some causal connection between the accident and the automobile allegedly involved for coverage to exist holding that to show a causal connection the plaintiff must demonstrate a relationship between the misconduct and the plaintiffs injury holding that there must be a causal connection between the advertising activity and the injury alleged in the underlying complaint holding that liability arises out of an event so long as there is a causal connection between the event and the liability