The United States Court of Appeals for the Ninth Circuit, applying California law, has affirmed a district court’s determination that California Insurance Code § 533 barred indemnity and defense costs coverage for a lawsuit alleging the insured conspired to steal (and allegedly stole) clients and employees of a rival talent management agency. United Talent Agency, LLC v. Markel Am. Ins. Co., 2025 WL 869213 (9th Cir. Mar. 20, 2025) (unpublished). Section 533 provides that “[a]n insurer is not liable for a loss caused by the wilful [sic] act of the insured.”