(concurring). The exclusionary language used by the insurer in the insured’s policy provides that coverage will be precluded where "bodily injury [is] expected or intended by an insured person.”1 Because this language is analogous to that used by the insurer in Metropolitan *574Property & Liability Ins Co v DiCicco, 432 Mich 656, 676; 443 NW2d 734 (1989), we must apply the subjective standard, as interpreted in DiCicco, to the facts of this case. Moreover, in the instant case, we must evaluate the one exception to the exclusionary language, i.e., whether the insured, stipulated by the parties to be insane for the purposes of plaintiff’s dispositive motion, formed the requisite intent to intend the consequences of his actions.
As indicated by the majority, the trial court denied plaintiff’s motion for summary disposition, finding that the exclusion did not preclude coverage because the insured could not be found to have intended or expected to kill the decedent and frighten his family. The Court of Appeals affirmed.2 Before granting leave to appeal, we ordered the trial judge to ascertain the scope and content of the stipulation that was made by the parties for the purpose of plaintiff’s motion. At the conclusion of the hearing, the trial court opined "that the scope of the stipulation was that Mr. Frost was insane and did not have the mental capacity to appreciate the wrongfulness of his acts to form the requisite mental intent to commit murder or some type of assault.” We granted leave to appeal.3
I
The majority has identified the numerous rules of insurance contract construction on which the Court must rely to interpret an insurance contract.4 It is safe to assume that these rules of construction have a proinsured, procoverage bias, *575reflecting a belief that in the typical situation where a private individual, as opposed to a business entity, is purchasing insurance from an insurer, the parties do not share equal bargaining strength. Powers v DAIIE, 427 Mich 602, 608; 398 NW2d 411 (1986) (Williams, C.J.). Nevertheless, we have also consistently followed the rule of construction that rejects the temptation to rewrite the plain and unambiguous meaning of a policy under the guise of interpretation. We will not create an ambiguity where none exists. Upjohn Co v New Hampshire Ins Co, 438 Mich 197, 206-207; 476 NW2d 392 (1991) (opinion of Riley, J.).5
Contrary to the expansive approach in evaluating coverage language,6 we have taken a fairly narrow approach to interpreting exclusionary language in insurance contracts. DiCicco, supra at 672. We have placed a heavy burden on the insurer to draft exclusionary clauses in clear language comprehensible to lay persons for an exclusion to be operative against the insured. DiCicco, supra at 665; Upjohn, supra at 206. In short, the *576exclusionary language must be clear and unambiguous. Id.
II
Insurers incorporate exclusionary provisions to deter intentional losses that are consciously and deliberately brought about by the insured.7 The instant case presents the Court with the opportunity to explore the one limitation on the policy exclusion for intentional acts,8 i.e., the requirement that the insured must intentionally cause the injury to a third party.9 The difficulty in this case is that the insured, who was stipulated to be insane at the time of committing the act, must be proven to have had the requisite mental capacity to commit an intentional act for the purpose of summary disposition.
In DiCicco, we adopted the subjective standard to measure the intent of the insured where the exclusion precludes coverage where "bodily injury [is] expected or intended from the standpoint of the insured.”10 The subjective standard, however, was not strictly applied. Had the Court applied a purely subjective standard, the exclusion would only apply when the insured committed the act resulting in a loss with the actual specific intent to *577bring about that loss. This Court, however, wisely rejected the pure subjective standard and, instead, blended the subjective requirement with a policy-based approach. DiCicco, supra at 679, 682 (opinion of Riley, C.J.) ("[although the defendant denies any intent to injure, his actions speak louder than [his] words”). See also id. at 718, n 12 (opinion of Boyle, J.) ("[t]hus, as Justice Archer observes, post, p 731, n 11, the insured need not intend the actual bodily injury inflicted in order to fall under the exclusionary clause”), id. at 731, n 11 (opinion of Archer, J.) ("I wish to make it clear that the insured need not intend the actual bodily injury inflicted in order to fall within the instant exclusionary clause. It is sufficient that the fact-finder conclude the insured subjectively expected some type of harm reasonably foreseeable from the insured’s standpoint”) (emphasis in original). The difference between these approaches turns on whether the insured had intended the specific injury that in fact occurred, or whether the insured possessed a general intent to intend some injury. The general intent to injure is best characterized as requiring: (1) that the insured intended both the act as well as the infliction of an injury, and (2) that once it is found that some harm was intended, it is immaterial that the actual harm caused is of a different character or magnitude than that intended. Under our approach, the insured’s intent is inferred from the nature and type of conduct that led to the loss.11 It is not necessary *578to prove that the insured intended to specifically harm the individual.
The majority’s application of the facts to the above-quoted rule is in accord with the DiCicco principle. Although insane, the insured intended to kill the decedent because
we know that Mr. Frost left his home, stating his intentions. We also know that he drove to Gary Churchman’s house, knocked on his door, and shot him numerous times. He then threatened. Beulah Churchman, left the house, and killed himself.
It is apparent from these facts that Mr. Frost intended to injure Gary Churchman and expected at least to seriously harm him. No other interpretation is possible. Therefore, we find that Henry Gordon Frost indeed intended or expected the resulting harm he caused. [Mallett, J., ante, p 568.]
I agree with this observation. The insured’s intent to murder Churchman is inferred from the deliberate nature and the intentional type of conduct that led to his death. Therefore, summary disposition in favor of the plaintiff insurer must be entered.
In dissent, Justice Levin advocates the adoption of a per se rule, finding that if an insane individual does not have the mental capacity to commit murder under the criminal law, that person is not capable of intending or expecting the consequences of his actions for the purpose of the exclusionary language used by Auto-Owners. Levin, J., post, p 584. I cannot agree with this argument.
The appropriate test for measuring the mental capacity of the insured to form the requisite intent must be consistent with the understood purpose of the exclusion, not the criminal law. As we stated *579earlier in this opinion, the underlying purpose of an exclusionary clause is not to afford compensation to the person who suffered the injury at the hands of the insured. Nor is moral culpability the dispositive issue. Rather, the purpose is to deter the intentional conduct that the insurer expressly precludes from coverage.12
In addition, given the nature of the subjective standard of measuring the intent of the insured that we adopted in DiCicco — that the insured need not intend the actual bodily injury inflicted — the rule advanced by Justice Levin cannot be adopted. Under Justice Levin’s analysis, the Court would be adopting the pure subjective standard. In DiCicco, we unanimously rejected that standard, and concluded that the insurer need only establish that the insured intended to cause the victim some type of harm, not that he specifically intended to cause the injury as a consequence of his action. DiCicco, supra at 679, 682 (opinion of Riley, C.J.); id. at 718, n 12 (opinion of Boyle, J.); id. at 731, n 11 (opinion of Archer, J.). Because Justice Levin has not offered a persuasive reason to adopt the pure subjective standard for insane individuals, or any reason to retrench from the policy-blended subjective standard that we adopted in DiCicco, his argument must also be rejected.
III
The true goal of the intentional act exclusion is deterrence. Given the exclusionary language used by Auto-Owners, and the application of the policy-blended subjective standard that we unanimously adopted in DiCicco, we must conclude that while insane, the insured intended to kill Churchman. *580Accordingly, the exclusionary provision of Auto-Owners policy precludes coverage.13
Griffin, J., concurred with Riley, J.My views on this matter are unchanged from those I set forth in my separate opinion in Metropolitan Property & Liability Ins Co v DiCicco, 432 Mich 656, 676-678; 443 NW2d 734 (1989). In DiCicco, I argued that where a homeowner’s insurance policy includes an exclusionary clause which provides that the insurer will not cover "bodily injury or property damage which is either expected or intended from the standpoint of the insured,” id. at 672, an objective standard should be used to measure the intent of the insured. Id. at 676. However, a majority of this Court concluded that the subjective standard should be used to measure the intent of the insured in light of the relevant exclusionary language. Id. at 709-710 (opinion of Boyle, J.), 730 (opinion of Archer, J.), 737 (opinion of Cavanagh, J.), and 756 (opinion of Levin, J.). In the instant case, as in DiCicco, the majority has once again employed the subjective standard in light of the exclusionary language, and found that the insured, an insane individual, is able to "intend or expect the results of the injuries he causes.” Mallett, J., ante, p 563. While I agree with the majority’s holding, I write separately to further explain my reasoning.
184 Mich App 699; 459 NW2d 24 (1990).
438 Mich 862 (1991).
Mallett, J., ante, pp 566-567.
As we have previously stated:
"An insurance policy is a contract and should be interpreted according to its plain meaning. The court is mindful of the rule of law that where the provisions of an insurance policy are uncertain or ambiguous, or the meaning is not clear, that those terms should be given such interpretation or construction as is most favorable to the insured. This rule does not mean, however, that the plain meaning of plain words should be perverted, or that a word or phrase, the meaning of which is specific and well recognized, should be given some alien construction merely for the purpose of benefiting the insured.” [Wozniak v John Hancock Mut Life Ins Co, 288 Mich 612, 615; 286 NW 99 (1939).]
The insurer’s duty to provide a defense extends to allegations which even arguably come within the policy coverage. [Polkow v Citizens Ins Co of America, 438 Mich 174, 180; 476 NW2d 382 (1991). Emphasis added.]
See Keeton & Widiss, Insurance Law, § 5.4(d), p 518; 10 Couch, Insurance, 2d (rev ed), § 41:672, pp 681-682.
There is, of course, a distinction between "intending” the result of one’s volitional act, or “expecting” the consequence of completing a deliberate act. I would only hold that the insured’s intent is inferred from the nature of the act — announcing his intention, driving home to obtain his gun, driving over to Churchman’s house, deceptively calling him out on his porch, following him through the house to complete the job, telling the witnesses that they ought to keep quiet, and finally killing himself — and that we need not reach the issue whether he "expected” to kill Churchman.
10 Couch, Insurance, 2d (rev ed), § 41:676, pp 686-688; § 41:684, pp 694-695.
See n 1.
Under the objective standard that I advocated the Court adopt in DiCicco, supra at 676-678, the insured is presumed to have intended the consequences of his activity. Thus, as the objective standard applies to the determination whether the insured intended to do an act from which the injury or loss resulted, the purely subjective standard would focus on whether the insured had the conscious objective to bring about the injury or loss in fact resulting from his conduct.
10 Couch, Insurance, 2d (rev ed), § 41:676, pp 686-688; § 41:684, pp 694-695.
I agree with the majority that there is no conflict in the Court of Appeals regarding this issue. Mallett, J., ante, pp 569-570. As we stated in DiCieco, we must first evaluate the language of the exclusion, and then determine which standard to apply. The language used by the insurer in Transameriea Ins Corp of America v Boughton, 177 Mich App 253; 440 NW2d 922 (1989), required the Court to use the subjective standard in evaluating the facts in that case. The Boughton language is analogous to the language used by the insurer in this case, and, therefore, the result is consistent with this opinion. However, the language used by the insurers in Allstate Ins Co v Miller, 175 Mich App 515; 438 NW2d 638 (1989), Allstate Ins Co v Miller (On Remand), 185 Mich App 345; 460 NW2d 612 (1990), and Mattson v Farmers Ins Exchange, 181 Mich App 419; 450 NW2d 54 (1989), used language requiring the application of the objective standard. Therefore, the objective standard controlled the resolution of that case. In sum, there is no conflict with the Court of Appeals decisions.