How have courts interpreted exclusionary language in a personal injury contract?

"Strictly construing the exclusionary language against the insurer [citation], and reading this contract as a reasonable policyholder would read it [citation], we cannot find the limitation adequately conspic- uous [sic]. The definition of the insured, appearing at the outset of the liability section, gives every indication that a permissive driver stands in the same position as the insured and receives the same coverage. The average policyholder would reach the same conclusion by continuing to read the policy. The coverage limitation for permissive drivers is not contained within one of the subheadings that might alert the reader to a partial exclusion. Rather it appears within a subsection whose ordinary language would not encompass the limitation and is surrounded by language that has nothing to do with exclusions or limitations on coverage." (Jauregui v. Mid-Century Ins. Co., supra, 1 Cal.App.4th at pp. 1549-1550.) In concluding that the insurer failed to satisfy its burden of displaying exclusionary language conspicuously, the court noted that, "the average lay reader, attempting to locate coverage provided for permissive drivers, would have a difficult time locating the limiting language and is not required to conduct such an arduous search for camouflaged exclusions." (Id. at p. 1550.)