News & Analysis as of

Property Damage Summary Judgment

Cozen O'Connor

Claims Notes: July 2025

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Jones owned an eight-acre property with a half-acre pond in front of his house. Hatcher, a broker, offered to secure cheaper insurance, asking Jones to sign a single-page application without questions. Hatcher inspected and...more

McGinnis Lochridge

Are Statute of Limitations Battles Becoming the New Frontline in Water Injection Cases?

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When your neighbor's wastewater tanks your oil wells, when exactly can you sue? A Texas court wrestles with a timing question reshaping industry battles....more

Zelle  LLP

Massachusetts Collapse Decision Highlights Importance of Careful Underwriting

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During the underwriting process, carriers should review affirmative coverages not only to ensure consistency with applicable exclusions but also to make sure that the coverages themselves are internally consistent. Failure to...more

Cozen O'Connor

Insurer’s Use of Conflicting Reports Not Bad Faith, Says Court

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In El Dueno, LLC v. Mid-Century Insurance Company (2025 WL 1540329) (10th Cir. 2025)), the Tenth Circuit Court of Appeals affirmed summary judgement on behalf of the insurer on the basis that the insurer did not act in bad...more

Carlton Fields

Connecticut Federal Court Construes Ambiguous Policy Exclusion in Favor of Coverage, but Rejects Bad Faith Claim

Carlton Fields on

In A Priori Family Office LLC v. Valley Forge Insurance Co., the U.S. District Court for the District of Connecticut found the undefined term “surface water” in an all-risk insurance policy’s water exclusion ambiguous, so...more

Zelle  LLP

Holding an Insured to its Duties and Burdens

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Once in a while, there is an insurance case that addresses numerous “common” issues and reaffirms the parties’ respective duties in supporting and adjusting claims, promptly making repairs, and mitigating loss. The recent...more

Cozen O'Connor

Noncompliance With Policy’s “Duties After Loss” Provision Leads to Denial of Fire Loss Claim

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In Caribe D. Billie v. Plymouth Rock Assurance Corp. et al, the U.S. District Court for the District of Connecticut granted Plymouth Rock Assurance Corp.’s (“Insurer”) motion for summary judgment, holding that the Insurer was...more

Husch Blackwell LLP

Wisconsin Court of Appeals Upholds Ordinance or Law Exclusion in Insurance Coverage Dispute

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In a recent decision, the Wisconsin Court of Appeals affirmed the application of an “Ordinance or Law Exclusion” in a business owner’s insurance policy issued by Germantown Mutual Insurance Company.[1] The case, involving...more

Cozen O'Connor

Court Weighs in on Determining “Period of Restoration”

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In Comprehensive Medical Center, Inc. v. State Farm Mutual Automobile Insurance Company, 2025 WL 416814 (9th Cir. 2025), the Ninth Circuit Court of Appeals affirmed the district court’s determination that the period of...more

Tyson & Mendes LLP

But I Didn’t Mean to Do It …

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As a father of three children, I have become intimately familiar with this defense to all manner of allegations (which, yes, often involve property damage). When it comes to coverage disputes, you often see insureds making...more

Zelle  LLP

Calif. Smoke Claim Ruling Gives Insurers Support On Denials

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In their recent Law360 guest article titled "Reconciling 2 Smoke Coverage Cases From California," the authors described a California appellate court's Feb. 7 opinion in Gharibian v. Wawanesa General Insurance Co. as an...more

Zelle  LLP

Concurrent Causation is Key – Fifth Circuit Holds Insured to its Causative Burden

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The United States Fifth Circuit Court of Appeals recently affirmed summary judgment granted by the bankruptcy court in favor of commercial property insurer in a Winter Storm Uri claim, holding that the insured motel owners...more

Zelle  LLP

Any is Not All and The Future is Not Now: The Contours of the Cosmetic Damage Exclusion Taking Shape

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In Iyengar v. Liberty Insurance Corporation, No. SA-21-CV-1091-FB, 2024 WL 5505300 (W.D. Tex. Dec. 13, 2024), District Judge Biery denied Plaintiffs’ Motion for Clarification regarding Magistrate Judge Bemporad’s...more

White and Williams LLP

A Matter of Circumstance: New York Court Finds Circumstantial Evidence Enough

In State Farm Fire & Cas. Co. a/s/o Miriam Perez v. Pentair Flow Techs., LLC No. 7:21-CV-6679, 2025 U.S. Dist. LEXIS 36875, the United States District Court for the Southern District of New York (District Court) reconsidered...more

Marshall Dennehey

Third District Court of Appeal Rules Affidavit Lacks Evidence Linking Damage to Tropical Storm Eta

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Thomas A. Bouchard, Jr. v. Citizens Prop. Ins. Corp., Fla. 3d DCA, No. 3D12-2202, February 19, 2025 - Thomas Bouchard, the appellant, appealed a final summary judgment order entered in favor of Citizens Property Insurance...more

Marshall Dennehey

Fourth District Court of Appeal: Noncompliance with Post-Loss Requirements Is a Contract Breach, No Prejudice to Insurer Needed

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Alton Forbes v. People’s Trust Ins. Co., Fla. 4th DCA, No. 4D2023-2375, January 8, 2025 - The Fourth District Court of Appeals ruled that the final judgment against the appellant stands because the appellant failed to comply...more

Cozen O'Connor

Lack of Insurable Interest Precludes Recovery for Property Damage

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In Ram Krishana Inc. d/b/a Motel 6 Sulphur v. Mt. Hawley Insurance Co. (2025 WL 371016) (S.D.N.Y. 2025)), the United States District Court for the Southern District of New York determined that the plaintiff lacked an...more

Marshall Dennehey

Fifth District Court of Appeal Rules Insurance Benefit Assignment to Roofing Contractor Invalid Under Florida Statute § 627.7152.

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Holding Insurance Companies Accountable, LLC v. Leonard Caruso v. American Integrity Insurance Company of Florida, Fla. 5th DCA, No. 5D2023-2810, January 3, 2025 - The homeowner reported roof damage to his homeowners...more

Carlton Fields

California Appellate Court Rules Wildfire Debris Does Not Qualify as “Direct Physical Loss” Under Homeowners Insurance Policy

Carlton Fields on

The Second Appellate District of the California Court of Appeal recently affirmed a lower court ruling that wildfire debris on an insured’s property did not qualify as “direct physical loss” within the meaning of a homeowners...more

Cozen O'Connor

Fifth Circuit Reaffirms Appraisal and Bad Faith Jurisprudence as Policyholders Continue to Probe for Opportunities

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The United States Court of Appeals for the Fifth Circuit upheld a summary judgment granted to the insurer over a policyholder’s argument that payment of an appraisal award and interest may extinguish an insurer’s liability...more

Zelle  LLP

Federal Court Correctly Concludes that a Simple Disagreement Between Experts Does Not Support a Claim for the Breach of the Duty...

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U.S. District Court Xavier Rodriguez of the United States District Court for the Western District of Texas recently issued a decision granting summary judgment for an insurance carrier in a first-party case involving alleged...more

Zelle  LLP

Federal Court Properly Applies Concurrent Causation and Rejects an “Expert” Opinion –Thompson v. State Farm Lloyds

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U.S. Magistrate Judge Andrew Edison of the United States District Court for the Southern District of Texas recently issued a decision granting summary judgment for an insurance carrier in a first-party case involving alleged...more

Rivkin Radler LLP

August 2024 New York Insurance Coverage Law Update

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Merchants Preferred Insurance Company filed a declaratory judgment action in New York seeking a declaration that it had no duty to defend or to indemnify its insureds in an underlying Florida personal injury action arising...more

Cozen O'Connor

The End of a "Forever War"?: Texas Supreme Court Answers Certified Question Concerning Appraisal

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In Rodriguez v. Safeco Ins. Co. of Ind. the Texas Supreme Court addressed a key issue concerning appraisal that was dividing lower Texas state courts and Texas federal district courts. The United States Court of Appeal for...more

Marshall Dennehey

Grappling With the Wear and Tear Exclusions of Homeowners’ Policies

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Chabad of Key Biscayne, Inc. v. Scottsdale Ins. Co., No. 22-13603 (11th Cir. 2023) - Chabad filed a claim for water damage after a drain or sewer pipe broke. The insurer denied the claim under the general water damage...more

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