Boyle, J.
(concurring). I agree with the majority that the insurer does not have a duty to defend in the underlying tort action, and I agree that the decision of the Court of Appeals should be affirmed. I also agree that in this context voluntary intoxication does not provide the insured with a defense to the operation of an intentional-acts exclusion. I write separately to state that because the insurance contract does not require an examination of the accidental nature of the event from the insured’s perspective to determine whether an "accident” that resulted in the officers’ bodily injuries was an occurrence, the accidental nature of the event must be viewed from the officers’ perspective. I would hold that the injuries received by the officers were the result of an accident, and that, therefore, the injuries were caused by an occurrence. I would also hold that because the officers’ injuries were caused by an occurrence, an examination of the intentional-acts exclusion is necessary. The language of the policy mandates that the insured’s subjective intent both to act and to injure be examined relative to the exclusion for intentional injuries. It is not disputed that the insured intentionally resisted arrest and intentionally bit the police officer. Because the insured fought with the officers for almost an hour in subfreezing weather, the officers’ injuries were expected or intended from the standpoint of the insured and are therefore excluded from coverage.
*603I
As the lead opinion sets forth, on remand from this Court the Court of Appeals reversed the decision of the trial court, which had ordered Group Insurance Company of Michigan (gicom) to defend its insured in the underlying negligence claim. Unpublished opinion per curiam, decided October 26, 1990 (Docket No. 127020). The Court held that "Smith’s voluntary ingestion of excessive amounts of alcohol resulting in his forcibly resisting arrest was not an 'accident’ within the meaning of the insurance policy’s definition of 'occurrence.’ ” It reasoned that because the insured admitted in his deposition that he intended to resist arrest, and because the insured "described his intentional physical acts of resistance, such as biting the officer,” it was "unwilling to hold that his voluntary intoxication and his wilful, unlawful resistance resulting in injury, was an 'accident,’ an undesigned contingency or something which happened by chance.”
Judge Murphy dissented and stated that, "the majority on remand has failed to address the issue framed by the Supreme Court.” He reasoned that, while an insured may not use voluntary intoxication to avoid an exclusion in an insurance contract, the insured’s voluntary intoxication was not relevant to the threshold issue of insurance coverage. According to Judge Murphy, there simply was nothing in the coverage clause, "the 'occurrence’ language,” that would "prevent[] acts committed by the insured as a result of intoxication from qualifying as occurrences under the policy.”
I agree with Judge Murphy’s conclusion. Because the language of the insurance contract does not specify the perspective from which to view an *604accident that results in bodily injury,1 the accidental nature of the incident must be evaluated from the standpoint of the injured person. The officers did not invite Smith’s attack, and thus their resultant bodily injuries were "caused by an occurrence.” I would further hold that because Smith admitted that he intended to resist arrest and intended to injure the officer by biting him, and because the underlying complaint is based on the insured’s intentional acts of "pushing, striking, punching, biting and kicking” the officers, gicom does not owe its insured, Smith, a duty to defend him in the underlying negligence claim.
ii
"Insurance policies have a common structure.” Fischer, The exclusion from insurance coverage of losses caused by the intentional acts of the insured: A policy in search of a justiñcation, 30 Santa Clara L R 95, 103 (1990). Policies describe what they cover, "the scope of coverage.” Id. After defining the scope of coverage, policies contain the " 'take aways,’ ” or exclusions. Id. There are, therefore, two ways in which an insurer may limit its duties toward its insured: it may draft its coverage clause to include only certain events, or it may specifically exclude events through an exclusionary clause. Id. at 105.2
*605The duty to defend exists if the allegations in the underlying complaint "even arguably” fall within acts covered by the policy. Allstate Ins Co v Freeman and Metropolitan Property & Liability Ins Co v DiCicco, 432 Mich 656, 662; 443 NW2d 734 (1989). It is the substance of the complaint that controls, and we focus on the "basis for the injury,” id., to resolve the arguable scope of coverage. See also Illinois Employers Ins of Wausau v Dragovich, 139 Mich App 502; 362 NW2d 767 (1984); Reurink Bros Star Silo, Inc v Maryland Casualty Co, 131 Mich App 139; 345 NW2d 659 (1983).3
This is not to say that liability insurance is litigation insurance. The duty to defend is limited by the exclusions in the insurance contract. Meridian Mut Ins Co v Hunt, 168 Mich App 672, 677; 425 NW2d 111 (1988). "The insurer is not required to defend against claims for damage expressly excluded from policy coverage. The exception in the policy is part of the contract between the parties.” Id.
Thus, gicom has a duty to defend Smith if the acts and injuries alleged in the underlying tort complaint arguably come within the scope of acts and injuries covered under the insurance contract with Smith’s parents. If, however, these acts and injuries also fall within the class of acts and injuries expressly excluded by the policy, coverage *606is precluded, and gicom does not owe Smith a duty to defend in the underlying tort action. As we held in Freeman/DiCicco, supra at 668, the analysis of the question "requires that we first determine whether coverage exists, and then whether an exclusion precludes coverage.”
III
The coverage clause in "Section n Coverages” of the policy issued by gicom provides:
This Company agrees to pay on behalf of the Insured all sums which the Insured shall become legally obligated to pay as damages because of bodily injury or property damage, to which this insurance applies, caused by an occurrence. This Company shall have the right and duty, at its own expense, to defend any suit against the insured seeking damages on account of such bodily injury or property damage, even if any of the allegations of the suit are groundless, false or fraudulent
In the "Additional Definitions” section of the policy, the definition of "occurrence” is:
[A]n accident, including injurious exposure to conditions, which results, during the policy term, in bodily injury or property damage.
Coverage exists if the injuries were "caused by an occurrence,” that is, if the act was an accident that resulted in bodily injury, it falls within the policy definition of "occurrence.” It is not disputed that the officers were injured. Gicom, however, argues that the bodily injuries suffered by the officers were not the result of an accident, and were therefore not a covered "occurrence.” I disagree.
*607In Freeman/DiCicco, supra at 670, we defined "accident” as "an undesigned contingency, a casualty, a happening by chance, something out of the usual course of things, unusual, fortuitous, not anticipated, and not naturally to be expected.” We also recognized that an accident is not limited only to unintentional acts. Id. at 670. We had no occasion in Freeman/DiCicco to determine from whose perspective the accidental nature of the event was to be viewed.
This Court defined "accident” in the context of an accident insurance policy in Guerdon Industries, Inc v Fidelity & Casualty Co of New York, 371 Mich 12, 18-19; 123 NW2d 143 (1963).
"An 'accident,’ within the meaning of policies of accident insurance, may be anything that begins to be, that happens, or that is a result which is not anticipated and is unforeseen and unexpected by the person injured or affected thereby — that is, takes place without the insured’s foresight or expectation and without design or intentional causation on his part. In other words, an accident is an undesigned contingency, a casualty, a happening by chance, something out of the usual course of things, unusual, fortuitous, not anticipated, and not naturally to be expected.” [Quoting 10 Couch, Insurance, 2d (rev ed), § 41:7, p 9. Emphasis added.][4]
However, while it is correct in the context of accident insurance to say that an accident is an event that takes place "without the insured’s foresight or expectation and without design or intentional causation on his part,” because the insured *608and the injured person are one and the same, see, generally, 43 Am Jur 2d, Insurance, §§ 1-3, pp 73-79, this conclusion does not follow in the context of analyzing a contract of liability insurance. In the latter context, the insured may or may not be the party injured. We therefore look to the words of the insurance contract at issue to determine from which perspective the parties intended to view the accidental nature of the event.
IV
As observed in Freeman/DiCicco, before 1966, a split of authority existed regarding the perspective from which to view the accidental nature of the injury claimed.5 Even where the insured intended to injure the victim, the majority of courts addressing the question held that the accidental nature of the injuries must be viewed from the victim’s standpoint. 6 Thus, the injuries were the result of an accident, and the insurer was liable.7
Competing policy questions dictated the conflicting results. On the one hand, individuals should not be indemnified for intentional injuries inflicted upon another. On the other hand, injured persons should be compensated for their losses. Viewing the accidental nature of the injury from the victim’s standpoint promoted the compensation policy.8 Those courts viewing the accidental nature of *609the injury from the insured’s standpoint promoted the deterrence policy.9
As a result of the competing policies and conflicting decisions, the National Bureau of Casualty Underwriters and the Mutual Insurance Rating Bureau revised the standard policy language in 1966 to make it clear that the accidental nature of the event was to be viewed from the insured’s perspective.10 The industry addressed the possibility of viewing the accidental nature of the event from the victim’s perspective by specifically providing that it was to be viewed "from the standpoint of the insured.”11
Because gicom’s policy is silent with respect to the question from whose perspective the "accident” is to be viewed, we are faced with answering the same question presented before the 1966 revision of liability insurance policy language. While other insurance policies include the viewpoint in their definitions of "occurrence,”12 the instant policy does not. It provides coverage for "occurrences” and defines occurrences as "accident[s] . . . which result[ ] ... in bodily injury or property damage.”
Where the policy is silent regarding perspective, the court must evaluate the accidental nature of the injury from the victim’s perspective. Ashland Oil, Inc v Miller Oil Purchasing Co, 678 F2d 1293 (CA 5, 1982). In Ashland Oil, the insured carried *610liability insurance through two different insurers. One had specified in the policy that the accidental nature of the occurrence should be evaluated from the insured’s standpoint and one had not. Because one policy did not specify the standpoint, and because Louisiana case law provided that such occurrences be evaluated from the standpoint of the injured party, the court held that, under the policy that did not specify the perspective, the accidental nature of the occurrence must be evaluated from the victim’s perspective. As a result, the intentional injection of hazardous materials into an oil company’s pipeline was an "occurrence” under one policy and was not an "occurrence” under the policy that provided that the damage be neither expected nor intended from the standpoint of the insured. Id. at 1320-1321.
We have not been directed to, nor has independent research disclosed, decisions in this jurisdiction holding that the accidental nature of an injury is to be viewed from the victim’s perspective in interpreting homeowners’ insurance policies. However, there is authority that holds that under general automobile liability policies injuries are accidents, even when intentionally inflicted. In State Farm Mut Automobile Ins Co v Coon, 46 Mich App 503; 208 NW2d 532 (1973), the Court of Appeals evaluated authority both from Michigan and from other jurisdictions and held that, where the insured intentionally drove his vehicle, striking a pedestrian, the accidental nature of the event should be viewed from the victim’s standpoint. The Court noted, however, that if the victim acted as the aggressor, the event would not be an accident, and coverage would not exist.
A law enforcement officer, acting within the scope of his duties, will not be deemed to have been the aggressor in an altercation. Tomlin v *611State Farm Mut Automobile Liability Ins Co, 95 Wis 2d 215; 290 NW2d 285 (1980). Thus, a state trooper who had stopped a vehicle and was stabbed by the driver was accidentally injured under the driver’s automobile liability policy. The court noted that the accidental nature of the injury must be viewed from the victim’s perspective. This was true in general liability policies, and the court saw no reason to apply a different rule to automobile liability policies. Furthermore, where the officer was acting within the scope of his duties as a law enforcement officer, he would not be deemed the aggressor who started the chain of events that led to his stabbing.
Similarly, where a garage owner shot a person during a dispute, the injuries were suffered accidentally when viewed from the victim’s perspective. New Amsterdam Casualty Co v Jones, 135 F2d 191 (CA 6, 1943). Analyzing and applying Michigan law, the court held that "whether the injury is an accident, is to be determined from the standpoint of the one suffering it, rather than from the standpoint of the one inflicting it . . . .” Id. at 193. The court stressed, however, that it was not the insured who was seeking indemnity in this instance, but, rather, it was the victim who had attempted to collect a judgment from the insurance company through garnishment proceedings.
In the absence of language in the insurance contract indicating an intent to the contrary, I agree that, because the officers were performing their duties as law enforcement officers, they did not act as aggressors in the instant case. From the officers’ perspective, Smith’s resisting arrest, which caused frostbite, broken ribs, and a bitten hand, were all undesigned contingencies, casualties, happenings by chance, out of the usual course of things, unusual, fortuitous, not anticipated, and *612not naturally to be expected. The injuries were the result of-an accident, and were, therefore, caused by an occurrence as required for coverage under gicom’s policy.13
The policy language itself supports this interpretation. Gicom has made it clear that it is able to specify the viewpoint to be used when it so desires. The intentional-acts exclusion in the gicom policy expressly states that the bodily injury that results from an insured’s acts may not be expected or intended from the standpoint of the insured. Had gicom wished to expressly provide the perspective from which to view the accidental nature of the injury, it could have done so in the definition of "occurrence.”
V
The conclusion that the injuries suffered by the officers were caused by an occurrence does not resolve the question of the insurer’s duty to defend. Gicom’s policy provides that it does not apply "to bodily injury or property damage which is either expected or intended from the standpoint of the Insured.” The language is unambiguous, Freeman/DiCicco, supra, and requires that we look to the subjective intent or expectation of the insured to determine whether the officers’ injuries will be excluded from coverage. Id.
The intentional-injury exclusion applies where the insured intended to act and also intended or expected to injure the victim. Id. at 718. Once the intent to act and the intent or expectation to injure are present, it is " 'immaterial that the actual harm caused was of a different character or *613magnitude from that intended by the insured . . . .’” Id., quoting anno: Construction and application of provision of liability insurance policy expressly excluding injuries intended or expected by insured, 31 ALR4th 957, 973.
While the insured stated that he was surprised to learn that the officers had been injured, he admitted intending to prevent his arrest. He also admitted intending to bite the officer to prevent the officer from "yank[ing] the side of [his] face off.” Thus, the insured intended to actively resist arrest, and intended to injure by biting the officer. Once the intent to injure is shown, it is irrelevant that the injury was different from that intended by the insured. Furthermore, the insured fought with the police officers for nearly an hour in subfreezing temperatures. "[T]o claim that the insured did not expect or intend to cause injury 'flies in the face of all reason, common sense and experience.’ ” Freeman/DiCicco, supra at 720, quoting CNA Ins Co v McGinnis, 282 Ark 90, 93; 666 SW2d 689 (1984). Certainly all "reason, common sense and experience” tell us that frostbite will occur from exposure to subfreezing temperatures.
Not only has the insured admitted intending to act and intending to injure the officers, but the plaintiffs’ complaint does not allege acts that arguably escape the exclusion and come within the policy coverage. We look beyond the nomenclature14 in the complaint to its substance, Freeman/ *614DiCicco, supra at 663; Dragovich, supra at 507, and focus on the "basis for the injury,” not the form of the complaint. Freeman/DiCicco, supra at 662. See also Dragovich, supra at 507.15
The underlying complaint alleges that Smith "negligently and repeatedly cause[d] injury to the Plaintiffs by pushing, striking, punching, biting and kicking the Plaintiffs on or about their bodies.” While the complaint earlier alleges that, because of his intoxication, Smith "lacked voluntary control over his actions,” Smith’s own deposition testimony belies this allegation. He admitted biting the officer and admitted resisting arrest. The basis for the officers’ injuries, therefore, was Smith’s intentional act and not negligence as expressly alleged in the complaint.
*615VI
The events and injuries of December 31, 1983, were an "occurrence” as defined in gicom’s policy. However, the bodily injuries suffered by the officers were intended or expected from the standpoint of its insured and are therefore specifically excluded under the policy. The insured intended to act and intended or expected to injure the officers. His conduct falls squarely within the intentional-acts exclusion as written in gicom’s policy. Furthermore, the allegations in the complaint do not arguably fall within the coverage of the insurance policy at issue here. The insured’s voluntary intoxication will not provide him with a defense against the operation of the intentional-acts exclusion. Gicom, therefore, owes Smith no duty to defend him under its insurance policy. I would affirm the decision of the Court of Appeals.
Gicom’s policy does not include in its definition of "occurrence” that the accident that results in bodily injury or property damage may not be expected or intended from the standpoint of the insured, language that is often found in the coverage clauses of other insurance policies.
For instance, many insurers limit the scope of coverage to only accidental conduct by drafting the policy’s coverage clause in terms of an occurrence as the covered event. "Occurrence” is then defined as "an accident which occurs during the policy period resulting in bodily injury or property damage 'neither expected nor intended from the standpoint of the insured.’ ” Fischer, supra at 105. Where this limita*605tion of the definition of accident does not appear in the coverage clause, insurers have drafted exclusionary clauses that specifically exclude from coverage "injury or loss 'expected or intended from the standpoint of the insured.’ ” Id.
Where several theories of liability are asserted in a complaint, some of which fall within policy coverage and some of which dp not, the insurer has a duty to defend if any of the theories asserted would be covered by the policy. Meridian Mut Ins Co v Hunt, 168 Mich App 672, 677; 425 NW2d 111 (1988). Doubt regarding the insurer’s duty to defend must be resolved in favor of the insured. Freeman/DiCicco, supra at 662.
4 While this Court in Guerdon Industries applied the definition to a liability insurance policy, the Court was not attempting to categorize an insured’s intentional act as an accident. Nor did the Court specifically hold from which perspective the accidental nature of the act must be viewed.
See Freeman/DiCicco, supra at 714-716, Rynearson, Exclusion of expected or intended personal injury or property damage under the occurrence deñnition of the standard comprehensive general liability policy, 19 Forum 513, 521-522 (1984), comment, The expansion of insurance coverage to include the intentional tortfeasor, 23 Loyola L R 122, 124-126 (1977), and note, Intentional injury exclusion clauses —What is insurance intent?, 32 Wayne L R 1523, 1524-1525 (1986).
Comment, n 5 supra at 124.
Id.
Note, n 5 supra at 1524.
Id.
Rynearson, n 5 supra at 513; comment, n 5 supra at 127; note, n 5 supra at 1524.
Comment, n 5 supra at 127.
For instance, the insurer in Frankenmuth Mut Ins Co v Piccard, 440 Mich 539, 547, n 12; 489 NW2d 422 (1992), specifically stated the viewpoint to be used. Its policy provides:
"[Ojccurrence” means an accident . . . which results in bodily injury or property damage neither expected nor intended from the standpoint of the insured.
Because the coverage clause does not specify that the accidental nature of the event that caused the officers’ injuries be viewed from the insured’s perspective, the insured’s voluntary intoxication is simply immaterial with respect to the coverage clause.
The negligence count in the complaint alleges that Smith
owed a duty to society, and to the Plaintiffs in particular, to abide by all laws and mores of society which include: not to drink excessive amounts of intoxicating liquors, when he knew, or should have known, that he would become intoxicated and as a result, violent; not to present oneself in public in an intoxicated state; not to create danger to himself and others by *614becoming unruly, violent and dangerous due to excessive consumption of intoxicating liquors; and to obey the lawful commands of a police officer engaged in the lawful scope of his duty.
The complaint further alleges that Smith
breached said duty to society, and to the Plaintiffs in particular, by: becoming so intoxicated that Defendant lacked voluntary control over his actions which resulted in violent, dangerous and unruly behavior; disobeying the lawful commands of police officers engaged in the lawful scope of their duties entrusted to them by society; and by further conducting himself in a negligent and grossly negligent manner so as to actually severely injure the Plaintiffs.
And the complaint alleges that Smith
negligently and repeatedly cause[d] injury to the Plaintiffs by pushing, striking, punching, biting and kicking the Plaintiffs on or about their bodies.
In Dragovich, where the victim sought compensation for "injuries he sustained when he was 'struck, pushed or physically assaulted,’ ” the Court held that the basis for the injury was the insured’s intentional act of assault. Because the policy excluded coverage for injury arising out of an assault or battery committed by the insured, the insurer had no duty to defend its insured.