Leonard v. State Farm Fire & Cas. Co

2025 Ohio 5089
CourtOhio Court of Appeals
DecidedNovember 10, 2025
DocketCA2024-07-091; CA2024-09-113
StatusPublished

This text of 2025 Ohio 5089 (Leonard v. State Farm Fire & Cas. Co) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Leonard v. State Farm Fire & Cas. Co, 2025 Ohio 5089 (Ohio Ct. App. 2025).

Opinion

[Cite as Leonard v. State Farm Fire & Cas. Co, 2025-Ohio-5089.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

BUTLER COUNTY

JAMES LEONARD, : CASE NOS. CA2024-07-091 Appellant, : CA2024-09-113

: - vs - OPINION AND : JUDGMENT ENTRY 11/10/2025 STATE FARM FIRE & CASUALTY CO., :

Appellee. :

CIVIL APPEAL FROM BUTLER COUNTY COURT OF COMMON PLEAS Case No. CV 2023 06 1145

Law Office of John H. Forg, and John H. Forg, III for appellant.

Gallagher, Gams, Tallan, Barnes & Littrell, LLP, and Lori E. Thomson, for appellee.

____________ OPINION

BYRNE, J.

{¶ 1} James Leonard appeals from the decision of the Butler County Court of

Common Pleas, General Division, which granted summary judgment in favor of State

Farm Fire & Casualty Co. and dismissed Leonard's claims arising out an insurance claim. Butler CA2024-07-091 CA2024-09-113

For the reasons described below, we affirm.

I. Factual and Procedural Background

A. Storm Damage and Insurance Claim

{¶ 2} Leonard owns a home located in Middletown, Ohio ("the residence"). State

Farm Fire & Casualty Co. ("State Farm") provided homeowner's insurance for the home

under a homeowner's policy ("the policy").

{¶ 3} In June 2022, a severe windstorm damaged the residence's roof. Leonard

later filed an insurance claim with State Farm. In October 2022, a State Farm adjustor

inspected the roof and determined that coverage existed. The adjustor determined that

the policy covered $4,989.12 in repairs, and a payable amount of $3,530.40. 1 State

Farm's repair estimate included replacement of 22 damaged shingles and a four-foot by

four-foot section of decking.

{¶ 4} Leonard separately retained a roofing contractor, Weather Guard Roofing,

Ltd. ("the roofing contractor"), to assess the storm damage and provide him with a repair

estimate. The roofing contractor provided Leonard with an estimate totaling $50,760.95.

{¶ 5} The significant difference between the two estimates was due to the roofing

contractor's estimate including replacement of the entire roof. In the written estimate, the

roofing contractor explained:

We received the [State Farm] estimate for repairs for [the insured.] After reviewing the approved scope, we sent a shingle sample out for proper identification to ensure the replacement shingles would be of like kind and quality, as well as compatible with what is currently on the roof. Once the shingle was removed, it was noticed that the roof has spaced decking. With the estimate provided by State Farm including replacing 4 square feet of decking, and replacing multiple shingles throughout the roof assembly, it would not be up to

1. The payable amount constituted the covered damages, less accrued depreciation and the policy's $1,000 deductible. -2- Butler CA2024-07-091 CA2024-09-113

code to install new shingles over the spaced decking. Our estimate includes laying over new OSB to bring the decking surface up to code and replacing all the shingles. Once we received the paperwork back in regards to the identification of the shingle, it was determined that there is no shingle on the market currently that is compatible with the shingles on the roof. This is yet another reason why a repair can not be completed, and a total roof replacement is needed.

{¶ 6} Thus, the roofing contractor's opinion that total roof replacement was

necessary was not based on the roofing contractor disagreeing with the State Farm

adjustor as to the extent of damage caused by the windstorm, but rather due to the roofing

contractor's determination that matching shingles were unavailable, as well as the roofing

contractor's discovery that the currently installed decking had gaps between the decking

sheets, which would not, according to the roofing contractor, conform to applicable

building codes.

B. Demand for Appraisal

{¶ 7} Leonard sent the roofing contractor's estimate to State Farm, but received

no response. In April 2023, Leonard sent an "appraisal demand letter" to State Farm

stating that he was invoking the policy's appraisal clause.

{¶ 8} In May 2023, State Farm responded to the appraisal demand letter in a

written correspondence. In the correspondence, State Farm directed Leonard to the

appraisal provision language in the policy and included an excerpt of that language in the

correspondence. In brief, the appraisal provision language ("the appraisal clause"), as set

forth in State Farm's correspondence, provided that if the insured and State Farm failed

to agree on the "amount of loss," relative to an insurance claim, that either party could

demand that the "amount of loss" be determined through the appraisal process.

{¶ 9} The appraisal clause provides, in summary, that each party would select an

appraiser and the appraisers would attempt to jointly determine the amount of loss. If the

-3- Butler CA2024-07-091 CA2024-09-113

appraisers agreed, the amount of the loss would be binding on the insured and State

Farm. If the appraisers failed to agree, an umpire would be selected to resolve any

differences.

{¶ 10} The appraisal clause also set out the following concerning the scope of the

appraisal:

h. Appraisal is only available to determine the amount of the loss of each item in dispute. The appraisers and the umpire have no authority to decide:

(1) any other questions of fact; (2) questions of law; (3) questions of coverage; (4) other contractual issues; or (5) to conduct appraisal on a class-wide basis.

{¶ 11} Based on these exclusions, State Farm asserted that the appraisal process

did not include questions concerning law or policy coverage and was only available to

determine the "amount of loss." State Farm asserted that this was not a case where the

parties disagreed on the amount of loss, but rather, the parties disagreed upon the scope

of repairs that would be covered under the policy, which could not be determined through

the appraisal process.

C. Complaint

{¶ 12} Dissatisfied with State Farm's response, in June 2023, Leonard filed a

complaint against State Farm in the Butler County Court of Common Pleas. The complaint

asserted three causes of action.

{¶ 13} In Count One, titled "Appraisal," Leonard recited the appraisal clause

language in State Farm's letter and asserted that by denying Leonard's request for

appraisal, State Farm had breached the policy and Leonard had suffered resulting

damages. Leonard also attached to his complaint, as an exhibit, the State Farm rejection

-4- Butler CA2024-07-091 CA2024-09-113

letter containing the appraisal clause.

{¶ 14} In Count Two, titled "Breach of Contract," Leonard asserted that State Farm

had breached the terms of the policy by its failure to "pay for the damages to the

Residence caused by the severe storm . . ."

{¶ 15} In Count Three, titled "Good Faith and Fair Dealing," Leonard asserted that

State Farm had violated a duty to deal with Leonard fairly and in good faith with respect

to the claims presented to it under the policy. Among other claims, Leonard asserted that

State Farm had acted "arbitrarily, capriciously and/or maliciously in refusing to settle the

Homeowner's Claim under circumstances that did not furnish a reasonable justification

for that refusal . . ."

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Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 5089, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leonard-v-state-farm-fire-cas-co-ohioctapp-2025.