What is the current state of the law on "sudden" use?

39 One argument that sometimes crops up in the cases is that the very fact a substantial number of courts have disagreed over the meaning of "sudden" shows the word is ambiguous. (See, e.g., New Castle County, supra, 933 F.2d at 1196 ["We agree with this assertion to a certain extent."]; Just v. Land Reclamation, Ltd., supra, 456 N.W.2d at p. 578 ["the fact that substantial conflicting authority exists ... merely serves to strengthen the conclusion that the terms are susceptible to more than one meaning, and thus ambiguous"].)