Most commercial property, and homeowners dwelling policies in are considered “all-risk” policies. “The term all-risk is given a broad and comprehensive meaning.” Wallach v. Rosengerg, 527 So.2d 1386, 1388 (Fla. 3rd DCA 1988). “The purpose of an all-risk policy is to protect against all risks except those expressly excluded.” Fayad v. Clarendon National Insurance Company, 899 So.2d 1082, 1089 (Fla. 2005).

“An all-risk policy provides ‘a special type of coverage extending to risks not usually covered under other insurance.’ And coverage is available for all loss not resulting from the insured’s willful misconduct or fraud unless the policy contains ‘a specific provision expressly excluding the loss from coverage.’ (internal citations omitted).  “This type of contract has been said to cover every conceivable loss or damage that may happen except when occasioned by the willful or fraudulent act or acts of the insured.” Egan v. Washington General Insurance Corp., 240 So.2d 875, 879 (Fla. 4th DCA 1970), See, Fayad v. Clarendon National Insurance Company, 899 So.2d 1082, 1085-86 (Fla. 2005)(“The specific type of insurance policy involved in this case is … an all-risk policy. Unless the policy expressly excludes the loss from coverage, this type of policy provides coverage for all fortuitous loss or damage other than that resulting from willful misconduct or fraudulent acts.”); Phoenix Insurance Co. v. Branch, 234 So.2d 396, 398 (Fla. 4th DCA 1970)(“In recent years, the so-called ‘all risks’ insurance policy has been used with increasing frequency. Such a policy is to be considered as creating a special type of coverage extending to risks not usually covered under other insurance, and recovery under the ‘all risks’ policy will as a rule be allowed for all fortuitous losses not resulting from misconduct or fraud unless the policy contains a specific provision expressly excluding the loss from coverage”).

“Once the insured establishes a loss that appears to be within the terms of the all-risk policy, the burden is on the insurer to prove that the loss was caused by an excluded risk.” “Starting with the well-settled law in Florida that exclusionary clauses are construed more strictly than coverage clauses, the insurer’s burden is even heavier under an all-risk policy.” Id.

“In deciding whether an all-risk policy excludes coverage for an insured’s claimed damages, we are guided by well-established principles of insurance contract interpretation. We begin with the guiding principle that insurance contracts are construed in accordance with “the plain language of the polic[y] as bargained for by the parties.” Auto-Owners Ins. Co. v. Anderson, 756 So.2d 29, 33 (Fla. 2000) (quoting Prudential Prop. & Cas. Ins. Co. v. Swindal, 622 So.2d 467, 470 (Fla.1993)) (alteration in original). However, if the salient policy language is susceptible to two reasonable interpretations, one providing coverage and the other excluding coverage, the policy is considered ambiguous. See Anderson, 756 So.2d at 34; Swire Pac. Holdings, Inc. v. Zurich Ins. Co., 845 So.2d 161, 165 (Fla. 2003).  Ambiguous coverage provisions are construed strictly against the insurer that drafted the policy and liberally in favor of the insured. See Anderson, 756 So.2d at 34; State Farm Fire & Cas. v. CTC Dev. Corp., 720 So.2d 1072, 1076 (Fla. 1998); Deni Assocs. of Florida, Inc. v. State Farm Fire & Cas. Ins. Co., 711 So.2d 1135, 1138 (Fla.1998). Further, ambiguous “exclusionary clauses are construed even more strictly against the insurer than coverage clauses.” Anderson, 756 So.2d at 34; see also Demshar v. AAA Con Auto Transport, Inc., 337 So.2d 963, 965 (Fla.1976) (“Exclusionary clauses in liability insurance policies are always strictly construed.”). Thus, the insurer is held responsible for clearly setting forth what damages are excluded from coverage under the terms of the policy.”  Fayad v. Clarendon National Insurance Company, 899 So.2d 1082 (Fla. 2005).