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[GEICO] seek[s] a declaratory judgment to determine GEICO's rights and
obligations for its insured [under an auto insurance policy (bảo hiểm oto) and an umbrella policy] for allegedly spreading a sexually transmitted disease (bệnh lây nhiễm qua đường tình dục) [HPV, which can causes genital warts (hột cơm, mụn cóc) and, sometimes, cervical cancer (ung thư cổ tử cung)] while voluntarily having unprotected sex (tình dục không an toàn) in the insured's automobile. GEICO's insured is defendant (bị đơn) M.B., and he allegedly gave the STD to defendant M.O.

M.O. demanded that GEICO pay her $1 million to resolve her claim against M.B., triggering GEICO to file this lawsuit (vụ kiện) ….

GEICO's amended complaint alleges that, for the two policies GEICO issued to M.B., liability coverage is identical for all relevant intents and purposes. GEICO seeks a declaratory judgment that these policies do not provide coverage for M.O.'s alleged injuries, and therefore GIECO has no duty to defend or indemnify M.B. against M.O.'s claim.

Among other things, GEICO alleges that the auto policy only applies to bodily injuries arising "out of the ownership, maintenance or use of the … auto," and that M.O.'s alleged damages have no nexus to the ownership, maintenance, or covered use of the 2014 Hyundai Genesis. In other words, the vehicle's covered use did not cause M.O.'s alleged injuries; instead, her injuries arose from an intervening cause—namely, her failure to prevent transmission of STDs by having unprotected sex. Likewise, the umbrella policy does not provide coverage because it only applies if the auto policy provides coverage. GEICO also asserts that various policy exclusions preclude coverage under the umbrella policy.

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