A Washington appeals court ruled that an unauthorized act of turning on an irrigation system that led to the rotting of an onion crop constituted an occurrence under a farm liability policy in Nationwide Mut. Ins. Co. v. Hayles, Inc., No. 24965-4-III, 2007 WL 14892 ( Wash. App. Div. 3 Jan. 4, 2007).

Clemente and Rosalva Ezquivel subleased a field from Hayles, Inc., on which they grew onions. Under the terms of the sublease, Hayles was to maintain the irrigation system and turn it on when the Ezquivels requested. Hayles turned the water on after the Ezquivel asked a Hayles employee to keep it off, and the onions rotted. The Ezquivels and Hayles settled, and the Ezquivels agreed to execute on the judgment against Nationwide, Hayles' farm liability insurer.