The Pennsylvania Superior Court affirmed the trial court’s decision, which ordered Nationwide to provide a defense to the parents in an underlying action concerning a young man’s death. The Kramers’ son hosted the decedent in the Kramers’ home while they were out of town. The decedent was found dead, and a coroner determined that the cause of death was a drug overdose. The decedent’s mother, Ms. Cruz, filed a wrongful death and survival action against the Kramers. Ms. Cruz alleged that the Kramer boy was widely known to use and sell drugs. Ms. Cruz asserted further that the Kramer boy was negligent in supplying the decedent with the drugs that caused his overdose. Relatedly, Ms. Cruz alleged in both the survival and wrongful death claims that the parents were negligent in allowing their son to use their home for such illicit activities. Nationwide insured the Kramers’ home. The insurer argued that it did not have to defend the Kramers, relying on coverage exclusions in their insurance policy, which applied when certain damages arise from criminal conduct or the use of controlled substances. The trial court ordered Nationwide to defend the Kramers. Nationwide appealed, and the Superior Court affirmed. The Court ruled that the wrongful death claim against the parents was not limited to bodily injury. The decedent’s family also sought other types of damages rooted in emotional distress, mental distress or injury, etc., none of which would have been the direct result of bodily harm to the decedent’s family itself. Since these types of damages did not fall under the ambit of the policy’s “bodily injury” definition, the policy’s controlled substance exclusion would not apply. Thus, having construed the relevant portions of the policy as excluding coverage as to some, but potentially not all, of the damages sought, the Court held that Nationwide would be obligated to pay out on the covered portions of the underlying claims if the Kramers are found liable. This obligation triggered Nationwide’s duty to defend the parents.