An ambiguous coverage provision meant the insurer was required to provide matching coverage as an extension of a covered claim. The case is Summer Pines Villas Homeowners Ass'n v. Owners Ins. Co., 2025 U.S. Dist. LEXIS 17917 (W.D. Wis. 2025).

What happened?

A spring hailstorm inflicted physical damage to the roofs and siding of multiple buildings owned by the Summer Pines Villas Homeowners Association. Summer Pines submitted a claim for those damages to its insurer, Owners Insurance, who conducted an investigation through a third party. A few months later, Summer Pines received a claim payment from Owners Insurance for $855,120, which covered the roof of each building and the damaged portions of the siding on only some of the buildings.

However, Summer Pines claimed Owners Insurance had not accounted for the physical mismatch between the existing, undamaged siding and the recently replaced siding and requested more coverage. Owners Insurance denied that claim, arguing the policy only applied to the “direct physical loss” for the buildings–the roofs and the damaged siding. When Summer Pines submitted a demand for an appraisal of the loss, Owners Insurance refused. The insurer claimed Summer Pines was arguing over a certain type of coverage, not the amount of the loss.