In coverage analysis, the cause of loss under named peril coverage must be by a specifically described peril in the form. An “all-risks” policy, as described by a Florida court, “ordinarily covers every loss that may happen except by fraudulent acts of the insured, excepting losses within a specific exclusion; insured has the burden of proving the property was lost or damaged and fortuity of loss, insurer has burden to prove loss was from an excluded clause. Although “all-risks” may increasingly be viewed as a misnomer, the term will probably continue in general use, to differentiate from named peril forms; hence, it’s continued use throughout this book.