Courts have considered whether uninsured auto coverage provided by affordable auto policies could cover drive-by shooting when the shooter and the victim were occupying autos and the shooter could not be identified nor has no auto insurance. Some counts have held that uninsured auto motorists’ coverage applies to such situations. These court decisions considered the vehicle occupied by the shooter to be an active accessory to the victim’s injury or death. Had the shooter not been in a vehicle he or she would not have shot the victim. Thus, the victim’s injures or death resulted from a covered auto accident under uninsured motorists’ coverage. Other courts have held that uninsured motorists’ coverage does not apply to drive-by shootings. These California courts have ruled that the victim’s injuries or death resulted from the shooting, which could just as easily have occurred while the victim and the shooter were outside the vehicle.