In Novotny v. Farmers Ins. Co., Inc., No. 05-0110, 2006 WL 468704 (Iowa App. Mar. 1, 2006), an Iowa appeals court held that homeowners failed to show water damage was covered under their insurance policy.

Clarence and Clyda Novotny owned a duplex house. They lived downstairs and rented out the upstairs unit. The duplex suffered water damage, the cause of which was disputed by the Novotnys and their insurer, Farmers.