caused them injuries of mind and body. . . . The petitions here would not have stated the complete causes of action without alleging the molestation and resulting injuries. . . .


14
Thus the penal violation exclusion logically and necessarily applies.


15
Id. Similarly, in American Commerce Insurance Co. v. Porto, 811 A.2d 1185 (R.I.2002), the court ruled that there was no coverage with respect to a negligent-supervision claim brought when a boy scout was sexually molested by a troop leader. The insurer prevailed because of a policy exclusion for a claim that "arises out of . . . the actual, alleged or threatened sexual molestation of a person." Id. at 1189 (internal quotation marks omitted). See also Stouffer & Knight v. Cont'l Cas. Co., 96 Wash.App. 741, 982 P.2d 105, 108 (1999) (exclusion for claims arising out of dishonest acts protected insurer against covering claim for negligent supervision brought by law-firm client whose funds were embezzled by secretary); Lee R. Russ & Thomas F. Segalla, 7 Couch on Insurance § 101:54 (3d ed. 1997) ("The phrase `arising out of' is frequently given a broader meaning than proximate cause. The phrase is considered to mean `flowing from' or `having its origin in," indicating that there only need be `a' causal connection, rather than a proximate causal connection."). Cf. Saenz v. Ins. Co. of Pa., 66 S.W.3d 444, 448 (Tex.App.2001) ("Under the Workers' Compensation Act, a claimant is required to prove that the injury for which she seeks compensation arose out of her employment. . . . [A]n injury arises out of employment if the employment is a producing cause—which means even if there are other causes for the injury, the employment need only be `a' cause."); Daniello v. Machise Express Co., 119 N.J.Super. 20, 289 A.2d 558, 560 (1972) ("An accident `arises out of employment' when in some manner it is due to the risk reasonably incidental to the employment, if the employment is a contributing cause of the accident resulting in the injury, and if the employment is a necessary