Nicole Goulet, Andrew Goulet v. Nationwide Insurance Company of America

District Court, E.D. Pennsylvania·Decided July 20, 2026·No. 2:25-cv-02852·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

NICOLE GOULET, ANDREW : CIVIL ACTION GOULET : : v. : NO. 25-2852 : NATIONWIDE INSURANCE : COMPANY OF AMERICA :

MEMORANDUM

MURPHY, J. July 20, 2026

This is an insurance dispute between homeowners and their insurer over the scope of a homeowner policy. A fire broke out at the homeowners’ residence, resulting in damage to part of the exterior siding. Everyone agrees that the policy covers the cost of replacing or repairing the fire-damaged siding. But they disagree as to whether the policy also covers replacing the rest of the siding, which no longer matches the new, replacement siding. The insurer denied coverage, asserting that the policy only covers the cost of replacing the fire-damaged siding. The homeowners sued, and now the insurer moves for summary judgment based on its reading of the policy. For the reasons explained below, we agree with the insurer’s reading and conclude that the policy clearly and unambiguously does not cover the replacement of the old siding. Under that reading, no material disputes of fact remain and we grant summary judgment in the insurer’s favor. I. FACTUAL BACKGROUND On January 22, 2025, a fire at the residence owned by plaintiffs Nicole and Andrew Goulet caused damage to the home’s aluminum siding, specifically on the rear elevation of the residence’s bump out section. DI 27 at ¶¶ 1-3. Plaintiffs’ home was insured under a Homeowner Policy (the Policy) issued by defendant Nationwide Insurance Company of America (Nationwide), known as an “all-risks” policy. Id. at ¶¶ 4-5. The Policy provides coverage for risks of loss that are not specifically excluded under the Policy. Id. at ¶ 5. In a section titled, “PERILS INSURED AGAINST[,]” the Policy states: SECTION I — PERILS INSURED AGAINST

A. Coverage A — Dwelling And Coverage B — Other Structures

1. We insure against direct physical loss to property described in Coverages A and B.

2. We do not insure, however, for loss: . . . c. Caused by: . . . (6) Any of the following: . . . (k) Mismatch of color between undamaged material and new material used to replace old, weathered or oxidized damaged material; or

(l) Mismatch between undamaged material and new material used to repair or replace damaged material due to outdated, obsolete or discontinued products. DI 19-5 at 27-29. The Policy includes a separate section titled, “EXCLUSIONS[,]” which states: “We do not insure for loss caused directly or indirectly by any of the following. Such loss is excluded regardless of any other cause or event contributing concurrently or in any sequence to the loss. These exclusions apply whether or not the loss event results in widespread damage or affects a substantial area.” Id. at 31. The Policy also contains a section titled, “CONDITIONS[,]” which governs the settlement of “[c]overed property losses” including costs for loss to dwellings. Id. at 34-36. This provision states: a. We will pay the cost to repair or replace, after application of deductible and 2 without deduction for depreciation, but not more than the least of the following amounts: (1) The limit of liability under this policy that applies to the building; (2) The replacement cost of that part of the building damaged for like construction and use on the same premises; or (3) The necessary amount actually spent to repair or replace the damaged building. If the building is rebuilt at a new premises, the cost described in (2) above is limited to the cost which would have been incurred if the building had been built at the original premises.

Id. at 36. Plaintiffs provided Nationwide with an estimate to replace the entirety of the siding on the dwelling, in the amount of $81,276, and submitted a claim demanding such payment. DI 27 at ¶¶ 9-10; DI 26 at ¶ 22. They obtained a report from Itel Laboratories, Inc. (Itel), which provided a report on the dwelling’s siding material. DI 19-5 at 194-95. The report concluded that the damaged siding material had “features that are unique to a product[s] that are no longer available” and that “[p]roducts manufactured with these specifications are no longer available.” Id. Accordingly, it determined that the damaged siding material “is discontinued” and that a national search revealed “no similar matches[.]” Id. at 195. At Nationwide’s request, a property restoration company called Puro-Tec inspected the siding and issued a report in which, upon reviewing the ITEL report, Puro-Tec concluded that “there are like, kind, and quality (LKQ) aluminum siding products currently available that can be used to replace the entire affected elevation” that “are compatible with the existing exterior cladding accessories and trim” — noting two specific products. Id. at 157-60. The report also stated that “[w]ith appropriate detailing and alignment, the repaired area will maintain a consistent and professional appearance without necessitating full replacement of undamaged elevations” and that “the new siding may 3 be painted to match the existing [siding]” to address any “color matching concerns.” Id. at 158. Nationwide issued a partial denial of coverage in which it denied the claim for siding that was not damaged by the fire based on its assertion that the Policy did not provide coverage for the mismatch between (1) the color of the undamaged material and new material used to replace

or repair old, weathered, or oxidized damaged material; or (2) the undamaged material and new material used to replace or repair damaged material due to obsolete, outdated, or discontinued products. DI 27 at ¶ 14; DI 19-5 at 153-55. As such, it only paid for the cost of replacing the entire elevation where the damaged siding was located, which included portions of the elevation that were undamaged — issuing a payment of $1,936.75. DI 27 at ¶¶ 11-13. It then issued a revised estimate to repair the siding using materials that the Puro-Tec report identified and issued a supplemental payment to plaintiffs of $398.80. Id. at ¶¶ 16-17. Plaintiffs then sued Nationwide, asserting breach of contract and bad faith claims. DI 1-4 at 6-10. Nationwide removed this action to federal court on June 3, 2025. DI 1. The parties filed cross motions for summary judgment in February of 2026, which we denied without

prejudice due to the parties’ failure to follow our policies and procedures on summary judgment motions. DI 16. Now, Nationwide again moves for summary judgment, while plaintiffs purport to seek summary judgment (without filing a motion to do so) in their response in opposition. DI 19; DI 26. II. MOTION AT ISSUE

Nationwide seeks summary judgment, asserting that there is no genuine fact in dispute and that it is entitled to judgment as a matter of law. DI 19; DI 20. It argues that plaintiffs have not established that their claim for the entirety of the dwelling’s siding is covered by 4 Nationwide’s Policy, and that there is no factual dispute that the siding included in that claim was not damaged by the fire. DI 20 at 9-23. According to Nationwide, the Policy clearly does not insure for loss that results from the mismatch of color between undamaged and new material upon replacing old, weathered, or oxidized damaged material, or the mismatch between

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Nicole Goulet, Andrew Goulet v. Nationwide Insurance Company of America, (E.D. Pa. 2026).

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