SILOAM SPRINGS HOTEL, LLC v. CENTURY SURETY COMPANY

KAUGER, J.,

concurring in

part/dissenting in part:

¶ 1 The United States District Court for the Western District of Oklahoma certified to this Court the following question:

Does the public policy of the State of Oklahoma prohibit enforcement of the Indoor Air Exclusion, which provides that the insurance afforded by the policy does not apply to “‘Bodily injury,’ ‘property damage,’ or ‘personal and advertising injury’ arising out of, caused by, or alleging to be contributed to in any way by any toxic, hazardous, noxious, irritating pathogenic *272or allergen qualities or characteristics of indoor air regardless of cause”?

Having determined that the question must be reformulated, I conclude that the Indoor Air Exclusion does not exclude coverage in the present ease.

FACTS

¶ 2 Defendant, Century Surety Company (insurer), issued an insurance policy to Plaintiff, Siloam Springs Hotel, L.L.C. (hotel), which provided general liability insurance coverage of the hotel in Siloam Springs, Arkansas, from November 13, 2012, through November 13, 2013. The policy stated that the insurer would cover that which the hotel was legally obligated to pay as a result of damages caused by bodily injury. The policy also included an “Indoor Air Exclusion,” which provided that the insurance does not apply to:

“Bodily injury,” “property damage,” or “personal and advertising injury” arising out of, caused by, or alleging to be contributed to in any way by any toxic, hazardous, noxious, irritating pathogenic or allergen qualities or characteristics of indoor air regardless of cause.

¶ 3 On January 17, 20l3, several guests in the hotel were allegedly injured due to carbon monoxide poisoning, The carbon monoxide entered the air after a sudden, accidental leak in the hotel’s indoor swimming pool heater. The hotel sought coverage under its insurance policy and the insurer denied coverage, relying on the Indoor Air Exclusion,

¶4 The hotel brought suit in Oklahoma state court, seeking a declaration that the policy did provide coverage for the injury of its guests. Based on complete diversity of citizenship, the insurer removed the case to the United States District Court for the Western District of Oklahoma. There, the parties filed cross-motions for summary judgment, and the district court granted summary judgment to the insurer.1 It concluded that the policy excluded coverage for bodily injury resulting from a one-time exposure to carbon monoxide. We are not bound by this conclusion. Rather, the determination of the ambiguity of the insurance contract is a question for state courts, not federal courts.

¶ 6 By virtue of the Supremacy Clause, we are governed by the decisions of the United States Supreme Court with respect to the federal constitution and federal law and we must pronounce rules of law that conform to extant Supreme Court jurisprudence. Nevertheless, nothing in the concept of supremacy or in any other principle of law requires subordination of state courts to the lower federal courts. Subject to decisions of the United States Supreme Court, we are free to promulgate judicial decisions grounded in our own interpretation of federal law. Where no Supreme Court directive exists, federal law is merely instructive in providing guidance on state law questions.2

¶ 7 Additionally, governmental authority to regulate the insurance business as an enterprise affected with public interest lies within the state’s recognized police power.3 Because attempts to place the insurance industry under congressional control as an activity in interstate commerce failed to take hold, the states continue to have plenary power to regulate this business in the public interest.4 *273State government’s police power to regulate the insurance industry is part of the exiting law in every insurance contract that is executed. That power, in contemplation of law, is a part of every such contract.5

¶8 The hotel appealed to the United States Court of Appeals for the Tenth Circuit.6 The Tenth Circuit remanded due to a potential lack of jurisdiction and did not address the merits of the case. The insurer’s notice of removal referred to the hotel as a “corporation” incorporated in OHahoma with its principal place of business in Arkansas. The hotel, however, is a limited liability company. The Tenth Circuit determined that for diversity purposes, a limited liability company assumes the citizenship of each of its members. Because the court could not determine whether complete diversity existed based on the record before it, it remanded the case. After determining that remand was appropriate, the Tenth Circuit- highlighted the particularly strong interest that states have in regulating the insurance industry. It then recommended:

Furthermore, although the parties argue the coverage issue exclusively by reference to generally applicable contract principles, it is far from clear the coverage issue at the center of this case is completely devoid of public policy implications. Given these factors, should the district court conclude on remand that diversity jurisdiction is proper, it would be well advised to move on to consider whether the state’s interest in insurance regulation would be best served by certifying the coverage questions at issue in this case to the appropriate state supreme court.

¶ 9 On -remand, the district court concluded that complete diversity of citizenship existed at the time of removal and that it therefore had jurisdiction over the case. It then certified to this Court the following question under the Revised Uniform Certification of Questions of Law Act7:

Does the public policy of the State of OHa-.homa prohibit enforcement of the Indoor Air Exclusion, which provides that the insurance afforded by the policy does not apply to ‘“Bodily injury,’ ‘property damage,’ or ‘personal and advertising injury’ arising out of, caused by, or alleging to be contributed to in any way by any toxic, hazardous, noxious, irritating pathogenic or allergen qualities or characteristics of indoor air regardless of cause”?8

I.

The Certified Question Must Necessarily Be Reformulated To Determine What The Indoor Air Exclusion Actually Excludes.

¶ 10 When responding to a certified question, this Court is not limited to the specifics posed by the certifying court. Title 20 O.S. 2011 § 1602.1 provides that “[t]he Supreme Court of this state may reformulate a question of law certified to it.” We have repeatedly exercised this discretion.9 And while the Court does not presume facts outside of those offered in the certification'order,10 it is *274not bound by the legal conclusion of the certifying court. The Revised Uniform Certification of Questions of Law Act places only two limitations on the Court’s answer: the answer must be determinative of an issue in pending litigation and there cannot be established or controlling law on the issue.11 Instead, when receiving a certified question, this Court “has authority to answer any question which may be determinative of an issue in the cause.”12

¶ 11 For example, in American Economy Insurance Co. v. Bogdahn, 2004 OK 9, ¶ 1, 89 P.3d 1051, the Court of Appeals for the Tenth Circuit certified a single question, which asked whether a specific individual was insured under an insurance policy.13 The question was reformulated into two questions, one addressing the ambiguity of a phrase in the policy, and another addressing the doctrine of reasonable expectations relating to insurance coverage.14

¶ 12 The certified question in the present case, whether Oklahoma’s public policy prohibits enforcement of the Indoor Air Exclusion, cannot be answered without first determining what the Indoor Air Exclusion actually excludes. If the meaning of the Indoor Ah’ Exclusion is unclear, then whether it violates Oklahoma’s public policy is also unclear. The Indoor Air Exclusion’s lack of clarity creates the central dispute of this case. The hotel reads it as covering a carbon monoxide leak, while the insurer does not. It is an issue that has been litigated in many other jurisdictions, with some courts determining that carbon monoxide leaks are covered by similar provisions and other courts determining that they are not.15 Ae-cordmgly, the question should be reformulated into two distinct inquiries.

1. Does the Indoor Air Exclusion, which provides that the insurance afforded by the policy does not apply to “ ‘[bjodily injury,’ ‘property damage,’ or ‘personal and advertising injury1 arising out of, caused by, or alleging to be contributed to in any way by any toxic, hazardous, noxious, irritating pathogenic or allergen qualities or characteristics of indoor air regardless of cause,” exclude application of the policy to bodily injury caused by carbon monoxide poisoning?
2. If so, does the public policy of the State of Oklahoma prohibit its enforcement?

¶ 13 The Tenth Circuit’s suggestion to the district court is in accord with this reformulation. In its recommendation reprinted in full above, the Tenth Circuit stated that the district court would be well advised to certify “the coverage questions at issue in this case.” It noted that it is far from clear that “coverage issue at the center of this case is completely devoid of public policy implications.” The public policy analysis of the exclusion will necessarily turn on the issue of what the policy covers, so the coverage issue must first be addressed.

II.

History of Pollution Exceptions.

¶ 14 The Indoor Air Exclusion is derivative of a pollution exclusion that has been found in insurance policies for decades. This category of exclusion has been heavily litigated, *275and a brief history of it and its variants helps place the present ease in context.

¶ 15 In the 1970⅛, the enactment of environmental statutes and increased public awareness about the harmful effects of pollution led to a significant rise in pollution-related insurance claims.16 Insurance companies responded by offering distinct environmental liability policies and limiting coverage in their general liability policies.17 Por example, coverage would be excluded for:

Bodily injury or property damage arising out of the discharge, dispersal, release or escape of smoke, vapors, fumes, acids, al-kalis, toxic chemicals, liquids or gases, waste materials or other irritants, contaminants or pollutants into or upon land, the atmosphere or any water course or body of water.18

Most policies included an exception to the exclusion if the discharge or escape was “sudden or accidental.”19 This exception produced “volumes of case law”20 and was “one of the most hotly litigated insurance coverage questions of the late 1980’s.”21 Some jurisdictions interpreted this language broadly to hold insurance companies liable in a number of cases, and the insurance companies responded.22

¶ 16 The standard language in many policies then became an “absolute pollution exclusion.”23 These provisions removed any exception for the “sudden and accidental” release of pollution, and removed the requirement that the pollution be discharged “into or upon land, the atmosphere or any watercourse or body of water.”24 Insurance industry regulators were concerned about the breadth of claims that the exclusion would prevent, noting that insurance companies could argue that the provision applies in situations outside environmental pollution.25 The insurance industry, however, represented to regulators that the provision would be applied only to traditional environmental pollution.26 Nevertheless, insurance companies did deny coverage for claims outside the traditional understanding of environmental pollution.27 Another torrent of litigation ensued, with some jurisdictions limiting the exclusion to traditional environmental pollution of the air, water, and soil, and not applying it to injuries caused by toxic substances that occurred in the normal course of business.28

¶ 17 It seems that the insurance industry has again responded. Continuing an apparent trend of broadening policy provisions in response to judicial decisions, the provision in the present case does not mention the word “pollution,” but instead refers to toxic, hazardous, noxious, or irritating qualities or characteristics of air. With this background in mind, we turn to the Indoor Air Exclusion.

III.

The Indoor Air Exclusion Does Not Exclude Coverage of a Sudden Carbon Monoxide Leak.

¶ 18 An insurance policy is not only a *276contract,29 but a contract of adhesion.30 An adhesion contract is a standardized document prepared entirely by one party and presented on a “take it or leave it” basis.31 Insurance contracts are contracts of adhesion because of the uneven bargaining power of the parties.32 To limit liability under a policy, an insurer must employ language that clearly and distinctively reveals that which it limits.33 If an insurance contract is ambiguous, the policy is construed most favorably to the insured and against the insurer.34 More specifically, words of inclusion are liberally construed in favor of the insured, and words of exclusion are strictly construed against the insurer.35 When interpreting an ambiguous provision, the meaning of the language is what a reasonable person in the position of the insured would have understood it, to mean.36 An insurance contract is ambiguous if it is susceptible to two interpretations from the standpoint of a reasonably prudent layperson.37

¶ 19 In Haworth v. Jantzen, 2006 OK 35, ¶ 1, 172 P.3d 193, this Court determined that an insurance policy was ambiguous and would be strictly construed against an insurer to provide coverage. The plaintiffs decedent was killed when his motorcycle was struck by the insured’s pickup truck as the insured was backing out of a wheat field onto a state highway. The policy excluded coverage of (1) bodily injury arising out of the use of a land motor vehicle subject to motor vehicle registration owned and operated by an insured person and (2) bodily injury arising out of the use of a land motor vehicle if the bodily injury occurs away from the insured premises.38 This Court concluded that the language was conflicting and ambiguous because an insured could reasonably interpret these provisions in multiple ways. The provisions could mean that bodily injury arising out of the use of a land motor vehicle is always excluded, only excluded if the vehicle *277is subject to registration, only excluded if the injury occurs away from the insured premises, or only excluded if the vehicle is not required to be registered and if the injury occurs away from the insured premises. Because the language of the exclusion was ambiguous, it was construed in favor of the insured to provide coverage.

¶20 Here, the Indoor Air Exclusion is likewise ambiguous because it is subject to multiple reasonable interpretations. Both interpretations put forth by the parties in this case are indeed reasonable. Again, the policy excludes coverage of:

“Bodily injury,” “property damage,” or “personal and advertising injury” .arising out of, caused by, or alleging to be contributed to in any way by any toxic, hazardous, noxious, irritating pathogenic or allergen qualities or characteristics of indoor air regardless of cause.

The hotel argues that the words “qualities or characteristics” limit coverage to an inherent and/or continuous attribute of the air quality. Under this interpretation, the provision would exclude injury arising from the development of mold, fungi, or some other ongoing condition of the air. In the hotel’s view, because the carbon monoxide leak was sudden and isolated, it was not a quality or characteristic of the air. The' word “quality” is defined as “an inherent feature.”39 It is therefore reasonable to conclude that a single and abrupt leak of carbon monoxide was not an inherent feature of the hotel’s air and that consequently the Indoor Air Exclusion does not exclude coverage.

¶21 The interpretation proffered by the insurer is also reasonable. It, focusing on the words “regardless of cause,” argues that the Indoor Air Exclusion does exclude coverage of one-time sudden infiltrations of carbon monoxide. Under its view, the carbon monoxide was a toxic characteristic of the indoor air caused by a sudden leak in the pool heater. This is a reasonable interpretation of the provision.

¶ 22 The Supreme Court of Nevada has already examined the same policy language in a suit involving the same insurer and already determined it ambiguous. It also determined that the policy language did not exclude coverage. Century Surety Co. v. Casino West, Inc., 329 P.3d 614 (Nev. 2014). In a strikingly similar case, the court was answering questions certified to it by the Ninth Circuit regarding interpretation of the Indoor Air Exclusion. Guests at the plaintiff hotel had died from carbon monoxide poisoning after a pool heater had malfunctioned, and the insurer denied coverage. The court concluded that the policy could be construed as excluding coverage for any injury caused by a problematic condition of the air regardless of whether it was temporary or permanent, or construed as excluding coverage for injury only if the problematic condition was permanent. Accordingly, the provision was deemed ambiguous and construed in favor of the hotel to provide coverage.

¶ 23 Similarly here, the provision is subject to more than one reasonable interpretation and is ambiguous.40 It could reasonably be interpreted as applying only to continuous air conditions or to both sudden and continuous air conditions. Because the provision is ambiguous, it will be construed in favor of the insured and words of exclusion will be strictly construed against the insurer.41 The meaning of the language is what a reasonable person in the position of the insured would have understood it to mean.42 Construing the provision in favor of the hotel, the Indoor Air Exclusion is limited to latent defects in the air, that is, to inherent characteristics of the air rather than sudden, isolated leaks. A reasonable person in the position of the hotel could have read the provision and understood it to apply only to mold, fungi, or some other *278ongoing condition of the air. Because the carbon monoxide leak in the present case was sudden, isolated, and temporary, the Indoor Air Exclusion does not exclude coverage of the resulting injuries. Because the Indoor Air exclusion did not exclude coverage, we need not address whether its enforcement would be prohibited by the strong public policy of the state.

Conclusion

¶ 24 The initial question posed by the United States District Court for the Western District addressed whether Oklahoma public policy would prevent enforcement of the Indoor Air Exclusion. Before that question could be answered, it was necessary to determine what the Indoor Air Exclusion excluded. The reach of the Indoor Air Exclusion is subject to multiple reasonable interpretations; it could arguably apply to either only permanent conditions of the air, or both temporary and permanent conditions of the air. Because the provision is subject to multiple interpretations and consequently ambiguous, it is properly construed against the insurer. Accordingly, the Indoor Air Exclusion does not exclude coverage of bodily injury resulting from sudden, accidental leaks of carbon monoxide.

. Siloam Springs Hotel, L.L.C. v. Century Sur. Co., CIV-13-572-M, 2014 WL 1924106 (W.D. Okla. May 14, 2014).

. Hollaway v. UNUM Life Ins. Co. of America, 2003 OK 90, ¶ 15, 89 P.3d 1022; Bogart v. CapRock Communications Corp., 2003 OK 38, ¶ 13, 69 P.3d 266; Akin v. Missouri Pacific Railroad Co., 1998 OK 102, ¶ 30, 977 P.2d 1040; United States v. Home Fed. S. & L. Ass'n of Tulsa, 1966 OK 135, ¶ 18, 418 P.2d 319; A.L. Lockhart v. Fretwell, 506 U.S. 364, 376, 113 S.Ct. 838, 846, 122 L.Ed.2d 180 (1993) (Thomas, J., concurring) ("The Supremacy Clause demands that state law yield to federal law, but neither federal supremacy nor any other principle of federal law requires that a state court’s interpretation of federal law give way to a (lower) federal court's interpretation.”). See, also, Steffel v. Thompson, 415 U.S. 452, 482, n.3, 94 S.Ct. 1209, 1227, n.3, 39 L.Ed.2d 505 (1974) (Rehnquist, J., concurring); United States ex rel. Lawrence v. Woods, 432 F.2d 1072, 1076 (7th Cir. 1970), cert. denied, 402 U.S. 983, 91 S.Ct. 1658, 29 L.Ed.2d 148 (1971).

. Insurance Co. of North America v. Welch, 1915 OK 914, ¶ 8, 49 Okla. 620, 154 P. 48.

. United States Department of the Treasury v. Fabe, 508 U.S. 491, 113 S.Ct. 2202, 124 L.Ed.2d 449 (1993).

. Sunray DX Oil Company v. Cole, 1967 OK 242, ¶ 18, 461 P,2d 305; Landowners, Oil and Gas Royalty Owners v. Oklahoma Corporation Commission, 1966 OK 225, ¶ 10, 420 P.2d 542.

. Siloam Springs Hotel, L.L.C. v. Century Sur. Co., 781 F.3d 1233 (10th Cir. 2015).

. Title 20 O.S. 2011 § 1602 provides that:

Power to Answer. The Supreme Court and the Court of Criminal Appeals may answer a question of law certified to it by a court of the United States, or by an appellate court of another state, or of a federally recognized Indian tribal government, or of Canada, a Canadian province or territoiy, Mexico, or a Mexican state, if the answer may be determinative of an issue in pending litigation in the certifying court and there is no controlling decision of the Supreme Court or Court of Criminal Appeals, constitutional provision, or statute of this state.

. Order Certifying Question to the OHahoma Supreme Court, March 21, 2016, p.2.

. E.g., Ball v. Wilshire Ins. Co., 2009 OK 38, ¶ 1, 221 P.3d 717; Tyler v. Shelter Mut. Ins. Co., 2008 OK 9, ¶ 1, 184 P.3d 496; McQueen, Rains & Tresch, LLP v. Citgo Petroleum Corp., 2008 OK 66, ¶ 1, 195 P.3d 35; McClure v. ConocoPhillips Co., 2006 OK 42, ¶ 1, 142 P.3d 390; Strong v. Laubach, 2004 OK 21, ¶ 1, 89 P.3d 1066; Hollaway v. UNUM Life Ins. Co. of Am., 2003 OK 90, ¶2, 89 P,3d 1022.

. Howard v. Zimmer, Inc., 2013 OK 17, ¶ 1, n.5, 299 P.3d 463; Jones v. Univ. of Cent. Okla., 1995 OK 138, ¶ 5, 910 P.2d 987.

. Title 20 O.S. 2011 § 1602, see note 3, supra.

. Hollaway v. UNUM Life Ins. Co. of Am., 2003 OK 90, ¶ 2, 89 P.3d 1022.

. "Whether Blake Bogdahn was a person insured under the uninsured motorist provisions of the American Economy policy issued to Hillcrest Pharmacy, Inc. as the named insured?”

. "Is the definition of an insured in the UM endorsement of the American Economy policy issued to Hillcrest Pharmacy, Inc. ambiguous, such that the doctrine of reasonable expectations can be applied to define Blake Bogdahn as an insured?” And, “[i]f so, does the statutorily mandated UM selection/rejection form create a reasonable expectation of coverage for Blake Bog-dahn, such that the policy must be reformed to provide such coverage?"

. Compare Assicurazioni Generali, S.p.A. v. Neil, 160 F.3d 997 (4th Cir. 1998) (concluding that an insurance policy exclusion barred coverage for injuries due to a carbon monoxide leak), with Reg'l Bank of Colorado, N.A. v. St. Paul Fire & Marine Ins. Co., 35 F.3d 494 (10th Cir. 1994) [concluding that a similar insurance policy exclusion did not bar coverage for injuries due to a carbon monoxide leak).

. In re Idleaire Techs. Corp., 08-10960(KG), 2009 WL 413117, at *4 (Bankr. D. Del. Feb. 18, 2009).

. In re Idleaire Techs. Corp., at *4.

. Doerr v. Mobil Oil Corp., 774 So.2d 119, 126 (La. 2000).

. Doerr, 774 So.2d at 126.

. In re Idleaire Techs. Corp,, at *5.

. Sulphuric Acid Trading Co., Inc. v. Greenwich Ins. Co., 211 S.W.3d 243, 250 (Tenn. Ct. App. 2006) (quoting J. Stempel, Interpretation of Insurance Contracts: Law and Strategy for Insurers and Policyholders 825 (1994)).

. Sulphuric Acid Trading Co., Inc., 211 S.W.3d at 250.

. Sulphuric Acid Trading Co., Inc., 211 S.W.3d at 250.

. Sulphuric Acid Trading Co., Inc., 211 S.W.3d at 250.

. In re Idleaire Techs. Corp., at *5.

. In re Idleaire Techs. Corp., at *5.

. This Court considered such a case involving the application of a total pollution exclusion to lead poisoning in a kidney dialysis center. Bituminous Cas. Corp. v. Cowen Const., Inc., 2002 OK 34, ¶ 3, 55 P.3d 1030.

. In re Idleaire Techs. Corp., at *6.

. Haworth v. Jantzen, 2006 OK 35, ¶ 13, 172 P.3d 193; American Economy Ins. Co. v. Bogdahn, 2004 OK 9, ¶ 8, 89 P.3d 1051; Spears v. Shelter Mutual Ins.Co., 2003 OK 66, ¶ 4, 73 P.3d 865. Brown v. Patel, 2007 OK 16, ¶ 11, 157, 157 P.3d 117 [Edmondson, J., writing for a majority of the court noted in fn. 8 that; Generally, the rules of construction governing the interpretation of contracts apply when construing obligations created by an insurance contract; and an insurance policy, a contract of adhesion, is construed to give reasonable effect to its provisions. Dodson v. St. Paul Ins. Co., 1991 OK 24, 812 P.2d 372, 376; National Life & Acc. Ins. Co. v. Cudjo, 1956 OK 305, 304 P.2d 322, 325. See also May v. Mid-Century Ins. Co., 2006 OK 100, ¶ 22, 151 P.3d 132, 140 (The rules of construction and analysis applicable to contracts govern equally insurance policies). A contract consists not only of its express language, but also of the obligations that are reasonably implied. Wright v. Fidelity & Deposit Co. of Md., 1935 OK 1215, 176 Olda. 274, 54 P.2d 1084, 1087. See 15 O.S. 2001 § 172. P.3d 117.]

. Max True Plastering Co. v. U.S. Fid. & Guar. Co., 1996 OK 28, ¶ 7, 912 P.2d 861; Wilson v. Travelers Ins. Co., 1980 OK 9, ¶ 8, 605 P.2d 1327.

. Max True Plastering Co., 1996 OK 28, ¶ 7, 912 P.2d 861; Rodgers v. Tecumseh Bank, 1988 OK 36, ¶ 14, 756 P.2d 1223.

. Max True Plastering Co., 1996 OK 28, ¶ 7, 912 P.2d 861; Wilson, 1980 OK 9, ¶ 8, 605 P.2d 1327.

. Haworth, 2006 OK 35, ¶ 17, 172 P.3d 193; Spears, 2003 OK 66, ¶ 7, 73 P.3d 865; Max True Plastering Co., 1996 OK 28, ¶ 7, 912 P.2d 861.

. Littlefield v. State Farm Fire & Cas. Co., 1993 OK 102, ¶ 7, 857 P.2d 65; Dodson v. St. Paul Ins. Co., 1991 OK 24, ¶ 13, 812 P.2d 372; Wilson v. Travelers Ins. Co., 1980 OK 9, ¶ 8, 605 P.2d 1327.

. Haworth. 2006 OK 35, ¶ 17, 172 P.3d 193; Spears, 2003 OK 66, ¶ 5, 73 P.3d 865; Simpson w Farmers Ins. Co., Inc., 1999 OK 51, ¶ 10, n.4, 981 P.2d 1262.

. Am. Econ. Ins. Co. v. Bogdahn, 2004 OK 9, ¶ 9, 89 P.3d 1051; Max True Plastering Co., 1996 OK 28, ¶ 2, 912 P.2d 861.

. Haworth, 2006 OK 35, ¶ 13, 172 P.3d 193; Spears, 2003 OK 66, ¶ 9, 73 P.3d 865; Cranfill v. Aetna Life Ins. Co., 2002 OK 26, ¶ 8, 49 P.3d 703.

. EXCLUSIONS Under PERSONAL LIABILITY-COVERAGE G and MEDICAL PAYMENTS TO OTHERS—COVERAGE H, we do not cover:

1. Bodily injury or property damage arising out of the ownership, maintenance, use or negligent entrustment of: ...

b. land motor vehicles subject to motor vehicle registration owned or operated or rented or loaned to an insured person ...
c. land motor vehicles, other than golf carts while used for golfing, if the bodily injury or property damage occurs away from the insured premises ...

. http://www.merriam-webster.com/dictionary/ quality.

. Haworth, 2006 OK 35, ¶ 13, 172 P.3d 193; Spears, 2003 OK 66, ¶ 9, 73 P.3d 865; Cranfill v. Aetna Life Ins. Co., 2002 OK 26, ¶ 8, 49 P.3d 703.

. Haworth, 2006 OK 35, ¶ 17, 172 P.3d 193; Spears, 2003 OK 66, ¶ 5, 73 P.3d 865; Simpson v. Farmers Ins. Co., Inc., 1999 OK 51, ¶ 10, n.4, 981 P.2d 1262.

. Am. Econ. Ins. Co. v. Bogdahn, 2004 OK 9, ¶ 9, 89 P.3d 1051; Max True Plastering Co., 1996 OK 28, ¶ 2, 912 P.2d 861.