Arreguin v. Farmers Ins. Co. of Idaho

180 P.3d 498, 145 Idaho 459, 2008 Ida. LEXIS 66
CourtIdaho Supreme Court
DecidedMarch 31, 2008
Docket33305
StatusPublished
Cited by30 cases

This text of 180 P.3d 498 (Arreguin v. Farmers Ins. Co. of Idaho) is published on Counsel Stack Legal Research, covering Idaho Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arreguin v. Farmers Ins. Co. of Idaho, 180 P.3d 498, 145 Idaho 459, 2008 Ida. LEXIS 66 (Idaho 2008).

Opinions

SUBSTITUTE OPINION.

THE PRIOR OPINION ISSUED JANUARY 31, 2008 IS HEREBY WITHDRAWN.

BURDICK, Justice.

This ease arises from an unpaid claim on a homeowners insurance policy. We must decide whether an exclusionary provision in the homeowners insurance policy is ambiguous.

I. FACTUAL AND PROCEDURAL BACKGROUND

Appellant Miguel Arreguin obtained a homeowners insurance policy from Respondent Farmers Insurance Company of Idaho (Farmers). Subsequent to the issuance of the policy, an agent of Farmers inspected the property and decided a detached garage on the property, which would normally be covered under the “Separate Structure” provision, should be excluded from coverage. As a result of that affirmative action, Farmers added an “Outbuilding” exclusionary provision to the policy and sent it to Arreguin. “Outbuilding” was not defined anywhere in the policy.

Arreguin made a claim on his policy after the detached garage sustained damage from a fire. Farmers denied Arreguin’s fire damage claim based on its conclusion that the detached garage was an “outbuilding” and, therefore, excluded from coverage under the policy.

Prior to the claim for fire damage, Arreguin made a claim for wind damage to the same detached garage. Though Farmers [461]*461first denied the claim as to the structural damage based on the “Outbuildings” exclusionary provision, it ultimately covered the damage.

Arreguin sued Farmers for breach of contract and insurance bad faith for failure to pay for the structural damage to the garage caused by the fire. The district court granted Farmers’s motion for summary judgment. Arreguin timely appealed to this Court.

II. STANDARD OF REVIEW

When reviewing a district court’s grant of summary judgment, this Court uses the same standard a district court uses when it rules on a summary judgment motion. Jordan v. Beeks, 135 Idaho 586, 589, 21 P.3d 908, 911 (2001). Summary judgment shall be rendered when “the pleadings, depositions, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” I.R.C.P. 56(e). This Court will liberally construe the record in favor of the party opposing the motion for summary judgment and will draw all reasonable inferences and conclusions in favor of that party. Farmers Ins. Co. of Idaho v. Talbot, 133 Idaho 428, 431, 987 P.2d 1043, 1046 (1999).

“When interpreting insurance policies, this Court applies the general rules of contract law subject to certain special canons of construction.” Clark v. Prudential Prop. & Cas. Ins. Co., 138 Idaho 538, 540, 66 P.3d 242, 244 (2003). “The general rule is that, because insurance contracts are adhesion contracts, typically not subject to negotiation between the parties, any ambiguity that exists in the contract ‘must be construed most strongly against the insurer.’” Talbot, 133 Idaho at 432, 987 P.2d at 1047 (quoting Mut. of Enumclaw Ins. Co. v. Roberts, 128 Idaho 232, 235, 912 P.2d 119, 122 (1996)). Whether an insurance policy is ambiguous is a question of law over which we exercise free review. Id.

III. ANALYSIS

Arreguin argues the “Outbuildings” exclusion in his homeowners insurance policy is ambiguous and, therefore, cannot be a basis for denial of coverage for the damage to the detached garage. Farmers argues the “Outbuildings” exclusion is unambiguous and that in any case Arreguin had notice the detached garage was an “outbuilding.” Finally, both parties assert they are entitled to an award of attorney fees on appeal. Each issue is addressed in turn.

A. The “Outbuildings” exclusionary provision is ambiguous.

Both parties agree that the detached garage is a “separate structure” within the meaning of the contract. However, Farmers denied coverage for the fire damage to the garage because it read the “Outbuildings” exclusionary provision to include the detached garage. Arreguin argues the “Outbuildings” exclusion is ambiguous and thus cannot be used to deny him coverage for the fire damage.

When we determine whether a policy is ambiguous we ask “whether the policy ‘is reasonably subject to conflicting interpretation.’ ” Talbot, 133 Idaho at 432, 987 P.2d at 1047 (quoting Mut. of Enumclaw v. Box, 127 Idaho 851, 853, 908 P.2d 153, 155 (1995) (quoting City of Boise v. Planet Ins. Co., 126 Idaho 51, 55, 878 P.2d 750, 754 (1994))). A provision that seeks to exclude the insurer’s coverage must be strictly construed in favor of the insured. Moss v. Mid-America Fire & Marine Ins. Co., 103 Idaho 298, 300, 647 P.2d 754, 756 (1982). The “burden is on the insurer to use clear and precise language if it wishes to restrict the scope of its coverage.” Id.

The insurance contract provides:

Coverage B — Separate Structures
We cover other structures on the residence premises separated from the dwelling, or connected to the dwelling by only a fence, utility line, sidewalk, driveway, patio or similar connection.
Wall-to-wall carpeting attached to the structure is part of the structure.
We do not cover land or the value of land, including land on which the separate structure is located or the cost to restore, replace, repair or rebuild land. If a covered [462]*462loss causes damage to a separate structure and to the land on the residence premises, we do not cover any increased cost to repair or rebuild the separate structure because of damage to the land.
We do not cover separate structures which are intended for use in business or which are actually used in whole or in part for business purposes.
RESTRICTIVE ENDORSEMENT
We agree not to cancel this policy for 30 days from the date shown above. You and we agree that this policy does not cover loss by / to:
1. ALL OUTBUILDINGS.
This endorsement is part of your policy. It supersedes and controls anything to the contrary. It is otherwise subject to all other terms of the policy.

(Emphasis in original).

An insurance policy is ambiguous when it is reasonably subject to differing interpretations. Armstrong v. Farmers Ins. Co. of Idaho, 143 Idaho 135, 137, 139 P.3d 737, 739 (2006). “Outbuildings” is not defined anywhere in the contract.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Lanningham v. Farm Bureau
Idaho Supreme Court, 2024
United Heritage v. Zech
516 P.3d 1035 (Idaho Supreme Court, 2022)
Progressive Northwest Insurance Company v. Lautenschlager
488 P.3d 509 (Idaho Supreme Court, 2021)
Greenwald v. Western Surety
Idaho Supreme Court, 2019
Greenwald v. Western Surety Co.
436 P.3d 1278 (Idaho Supreme Court, 2019)
McFarland v. Liberty Insurance Corp
Idaho Supreme Court, 2019
McFarland v. Liberty Ins. Corp.
434 P.3d 215 (Idaho Supreme Court, 2019)
Gearhart v. Mutual of Enumclaw Insurance Co.
378 P.3d 454 (Idaho Supreme Court, 2016)
Ferrell v. United Financial Casualty Co.
305 P.3d 529 (Idaho Supreme Court, 2013)
Rizzo v. State Farm Insurance
Idaho Supreme Court, 2013
Farm Bureau Mutual Insurance v. Eisenman
286 P.3d 185 (Idaho Supreme Court, 2012)
Glenn v. Union Pacific Railroad
2011 WY 126 (Wyoming Supreme Court, 2011)
Hoover v. Hunter
249 P.3d 851 (Idaho Supreme Court, 2011)
Thomas v. Thomas
249 P.3d 829 (Idaho Supreme Court, 2011)
Estate of Dumoulin Ex Rel. Dumoulin v. Cuna Mutual Group
248 P.3d 1252 (Idaho Supreme Court, 2011)
Hill v. American Family Mutual Insurance
249 P.3d 812 (Idaho Supreme Court, 2011)
Mortensen v. Stewart Title Guaranty Co.
235 P.3d 387 (Idaho Supreme Court, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
180 P.3d 498, 145 Idaho 459, 2008 Ida. LEXIS 66, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arreguin-v-farmers-ins-co-of-idaho-idaho-2008.