The judges of the Eighth Circuit reversed a district court ruling that an insurer was obligated to replace the policyholder’s entire roof to ensure the shingles would match. The case is Noonan v. Am. Family Mut. Ins. Co., 924 F.3d 1026 (8th Cir. 2019).

What Happened

The roof on the Noonans’ house was damaged in a severe thunderstorm. At the time of the damage, the Noonans had a “Gold Star Special Deluxe Form” policy (the Policy) with American Family Mutual Insurance (American Family). A “Gold Star Homeowners Amendatory Endorsement” had been attached to the Policy in 1999, which completely replaced the Policy’s Loss Valuation clause. In 2013, a second, Minnesota-specific endorsement was added to the Policy that stated American Family would not pay any increased costs associated with physically matching existing and replacement materials.