Daniels v. State Farm General Ins. Co. CA1/5

CourtCalifornia Court of Appeal
DecidedJanuary 13, 2026
DocketA168938
StatusUnpublished

This text of Daniels v. State Farm General Ins. Co. CA1/5 (Daniels v. State Farm General Ins. Co. CA1/5) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daniels v. State Farm General Ins. Co. CA1/5, (Cal. Ct. App. 2026).

Opinion

Filed 1/13/26 Daniels v. State Farm General Ins. Co. CA1/5 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FIVE

JACK DANIELS et al., Plaintiffs and Appellants, A168938 v. STATE FARM GENERAL (Napa County INSURANCE COMPANY et al., Super. Ct. No. 18CV001467) Defendants and Appellants.

In 2017, shortly after completing significant renovations, plaintiffs Jack and Gayle Daniels’s home was destroyed in the Atlas Fire. Their home was insured under a policy issued by State Farm General Insurance Company (State Farm). State Farm paid the Danielses the policy limits of approximately $3.4 million. On October 25, 2018, the Danielses sued State Farm and its agent for professional negligence and negligent misrepresentation, alleging that they had failed to increase the policy limits as requested. A jury found both the insurance agent and the Danielses partially at fault for the failure to increase the policy limits before the fire. It found total damages of $4,349,800. Following posttrial briefing, the trial court entered judgment denying an offset for State Farm’s prior payments under the policy and applying the comparative fault percentage allocated to

1 the Danielses, resulting in a judgment in favor of the Danielses for $2,218,398. On appeal, the Danielses contend the trial court erred in giving the comparative fault jury instruction and that substantial evidence does not support the jury’s finding of comparative fault. State Farm and its agent’s cross-appeal asserts that the trial court erred in applying the collateral source rule to bar the offset based on State Farm’s prior payment.1 We affirm. FACTUAL AND PROCEDURAL BACKGROUND I. Trial Evidence We summarize the facts relevant to the issues presented and in the light most favorable to the jury’s verdict. (Sacramento Sikh Society Bradshaw Temple v. Tatla (2013) 219 Cal.App.4th 1224, 1227.) In July 2016, the Danielses purchased a home in Napa. Jack Daniels contacted Alyssa Samrick, who was an agent at State Farm’s St. Helena insurance agency, about obtaining insurance for the Napa home. Daniels was a longtime customer of the agency, since the 1970’s when it was run by Norman Manzer. Manzer retired in 2008 and Samrick took over the agency. When the Danielses purchased the Napa home in July 2016, they were living in a condominium that was insured by State Farm, through Samrick. Jack Daniels told Samrick’s office that he intended to remodel the Napa home but wanted insurance for the house “ ‘as it existed’ ” in the meantime. Samrick prepared quotes for Jack Daniels and reviewed them with him by telephone. State Farm issued a homeowners policy for the period from July 25, 2016, to

1 State Farm and its agent are represented by the same counsel. We refer to State Farm and its agent collectively as defendants. We refer to the defendants individually as necessary in explaining the factual background.

2 July 25, 2017, with limits of $1,440,990 for the dwelling; $144,090 for dwelling extensions; and $1,080,675 for personal property. Jack Daniels did not request an increase in the personal property limits. Further, he did not tell Samrick about his wine collection or advise her that he had purchased new items for the Napa home. In February 2017, Jack Daniels called Samrick’s office and informed them that they were selling the condominium and would be moving into the Napa home. He also said that “ ‘the renovation was ongoing and [they] wanted to make sure that the insurance stayed the same until the renovation was over.’ ” He said they generally intended to spend about $1 million on the remodel, but he was not able to provide “ ‘a number at that point in time for what [their] limits should be increased to.’ ” The Danielses moved into the Napa home in late March 2017. Samrick spoke with Jack Daniels several times during the remodel process. She asked him for documentation of the specific work being done on the home or to schedule a visit to the property for an inspection. Daniels declined her request for an inspection until the project was completed. In July 2017, the policy was renewed with slightly higher limits of $1,485,600 for the dwelling; $148,560 for dwelling extensions; and $1,114,200 for personal property. The Danielses did not contact Samrick to change or question the limits. Jack Daniels never made an explicit request to raise the policy limits by a specific amount, but he testified he asked for a maximum increase of $1 million and then $2 million. On September 28 or 29, 2017, Jack Daniels contacted Samrick by telephone and told her that they had moved everything into the Napa home and had spent $2 million on the remodel, rather than the $1 million they initially anticipated. Samrick asked to come visit the property, but they did

3 not set a date because Mr. Daniels asked to wait until he finished the installation of high-end audiovisual equipment at the home. Samrick did not advise the underwriting department of the Danielses’ remodel project because she did not believe she had sufficient information to submit a policy change request. On October 8, 2017, the Napa home and its contents were destroyed in the Atlas Fire. The Danielses submitted a claim under their homeowners policy. State Farm paid the policy limits totaling $3,437,181.48, consisting of $2,295,697.48 for the dwelling (inclusive of all benefits available for trees and landscaping) and $1,141,484 for personal property.2 State Farm also paid $127,191.59 for personal property covered under a personal articles policy. The Danielses’ general contractor witness testified that the cost to rebuild the Napa home was $5,120,177. Their personal property appraisal witness testified that the actual cash value was $7,779,524.28. The replacement cost value of the Danielses’ personal property loss was approximately $11 million (inclusive of $8,555,187.53 for the Danielses’ wine collection. A consulting arborist testified that the appraisal value for replacement of the trees and shrubs was $220,582.

2 The parties stipulated to the policy limit amounts paid under the

State Farm policy for the loss the Danielses suffered due to the Atlas Fire. We note the trial also included evidence that the policy limits of the homeowners policy as of July 2017 were $1,485,600 for the dwelling; $148,560 for dwelling extensions; and $1,114,200 for personal property. The parties do not explain the discrepancy between the policy dwelling limits ($1,485,600) and the higher amount they stipulated State Farm paid for the dwelling limits ($2,295,697.48). Nor is the discrepancy relevant to our consideration of the issues on appeal.

4 II. Verdict The trial court granted State Farm’s motion for directed verdict on the professional negligence cause of action. It denied State Farm’s motion for directed verdict as to the negligent misrepresentation cause of action and as to emotional distress damages. The jury issued a special verdict finding that Samrick was professionally negligent and that her negligence was a substantial factor in causing harm to the Danielses. It found that Samrick was acting within the scope of her agency with State Farm when she harmed the Danielses. The jury awarded economic damages of $2,485,600 “related to the Home” and $1,864,200 “related to Personal Property.” It did not award any damages “related to Trees and Landscaping.” Nor did it award emotional distress damages. The jury also found the Danielses negligent in doing what was reasonable to obtain the homeowners insurance coverage limits they wanted.

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Bluebook (online)
Daniels v. State Farm General Ins. Co. CA1/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniels-v-state-farm-general-ins-co-ca15-calctapp-2026.