Higgins was sued by Cheryl Ingalls as a result of injuries she allegedly sustained during an argument between Higgins and his wife Maureen. In the subsequent lawsuit Higgins' insurer, State Farm, filed for a declaratory judgment on grounds that it was not obligated to cover his intentional wrongful acts. The trial court ordered a separate trial on State Farm's obligations before the trial on Ingall's lawsuit. Higgins and Ingalls contended this was improper, but on appeal the Fourth District agreed with the trial judge.