The United States Court of Appeals for the Ninth Circuit, applying California law, has held that California Insurance Code Section 533, which prohibits insurance coverage for willful conduct, does not require a final adjudication of such conduct in the underlying action. Aspen Specialty Ins. Co. v. Miller Barondess, LLP, 2023 WL 2523841 (9th Cir. Mar. 15, 2023). The court also found that the statute’s carveout for vicarious liability did not apply.