Tifton Mach. Works, Inc, v. Colony Ins., 480 S.E.2d 37, 39 (Ga.Ct.App. 1996) (citing Royal Indem. Co. v. Smith, 173 S.E.2d 738, 739 (Ga.Ct.App. 1970)) .

(Citation and punctuation omitted.) Tifton Machine Works v. Colony Ins. Co., 224 Ga. App. 19, 21-22 ( 480 SE2d 37) (1996). First, as the trial court observed, the defendant contractor in Sapp undertook to install hardwood floors in an existing home, and also to perform work on the crawlspace "to provide adequate ventilation and moisture barriers" to protect the floors.

Owners bore the burden of proof and persuasion to show that the exclusion applied. Tifton Machine Works v. Colony Ins. Co., 224 Ga. App. 19, 20 (1) ( 480 SE2d 37) (1996). In examining whether [Owners] met its burden, three rules of contract construction are applicable.

"[E]xclusions from coverage sought to be invoked must be strictly construed." Tifton Mach. Works, Inc. v. Colony Ins. Co., 224 Ga. App. 19, 20 480 S.E.2d 37 (1996). We also review several Georgia cases involving similar claims and similar policy terms.

Id." Tifton Machine Works v. Colony Ins. Co., 224 Ga. App. 19, 20 ( 480 S.E.2d 37) (1996). The policy in question includes in its definition of those insured, among others: (1) "[a]ny employee of the State of Georgia while operating an automobile owned by the State, its agencies or its instrumentalities" and (2) "[a]ny other person who is not a State Employee while using a vehicle with authorization, provided his/her actual operation or (if he/she is not operating) his/her other actual use is within the scope of such authorization.

In construing ambiguous language in insurance contracts, however, those ambiguities must be construed against the drafter. OCGA § 13-2-2 (5); Tifton Machine Works v. Colony Ins. Co., 224 Ga. App. 19, 20 (1) ( 480 S.E.2d 37) (1996). Here, we must examine the phrase as it appears in an insurance contract.

If "the phrasing of an insurance policy is so confusing that an average person could not make out the boundaries of the coverage," any ambiguities are construed against the insurer. Tifton Mach. Works, Inc. v. Colony Ins., 480 S.E.2d 37, 39 (Ga.Ct.App. 1996) (quotation marks omitted). But "the rule of liberal construction of an insurance policy cannot be used to create an ambiguity where none, in fact, exists."

Moreover, "[e]xclusions from coverage sought to be invoked must be strictly construed." SCI Liquidating , 181 F.3d at 1214–15 (quoting Tifton Mach. Works, Inc. v. Colony Ins. Co. , 224 Ga.App. 19, 20, 480 S.E.2d 37 (1996) ). In this vein, all ambiguities as to policy exclusions are interpreted in favor of coverage because "the insurer, having affirmatively expressed coverage through broad promises, assumes a duty to define any limitations on that coverage in clear and explicit terms."

And courts must strictly construe all exclusions that an insurer seeks to invoke. Tifton Mach. Works, Inc. v. Colony Ins. Co., 480 S.E.2d 37 (Ga.Ct.App. 1996). If a single claim in the underlying complaint triggers an insurer's duty to defend, the insurer must defend all of the claims asserted in the underlying action.

CompareValley Forge Ins. Co. v. Field , 670 F.3d 93, 99 (1st Cir. 2012) ("The term ‘care’ must be given a meaning and effect apart from the term ‘custody’ and the term ‘control.’ The three words are connected by the disjunctive ‘or,’ signalling they are to be read separately."), withTifton Mach. Works, Inc. v. Colony Ins. Co. , 224 Ga.App. 19, 480 S.E.2d 37, 39 (1996) ("The ‘care, custody or control’ language at issue is a term of art whose meaning varies depending on the underlying type of risk being insured. The cases applying this language may be viewed on a continuum.... Our courts also consider the purpose of the ‘care, custody or control’ language, which in the instant case, as in so many borderline cases, is to avoid a guarantee of workmanship."); cf.United States v. Obando , 891 F.3d 929, 934 (11th Cir. 2018) ("[T]he ordinary meaning of a term will yield when the term has ‘a technical meaning’ or is a ‘term of art.