In World Harvest Church v. Grange Mutual Casualty Co., 148 Ohio St. 3d 11, 68 N.E.3d 738 (Ohio 2016), reconsideration denied, 146 Ohio St. 3d 1473, 54 N.E.3d 1270., the Ohio Supreme Court upheld an abuse or molestation exclusion in a CGL policy which stated that there was no coverage under the policy for abuse or molestation “by anyone.” The Court found the policy language to be simple and unambiguous. The Court found that the language of the policy excluded coverage for abuse “by anyone,” including any liability premised upon the negligent employment, supervision, or retention of persons who committed the abuse or molestation.
