Rebecca Nelson v. State Farm Fire and Casualty Co

CourtCourt of Appeals for the Third Circuit
DecidedMarch 15, 2024
Docket23-1793
StatusUnpublished

This text of Rebecca Nelson v. State Farm Fire and Casualty Co (Rebecca Nelson v. State Farm Fire and Casualty Co) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rebecca Nelson v. State Farm Fire and Casualty Co, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _______________

No. 23-1793 _______________

REBECCA NELSON, Appellant

v.

STATE FARM FIRE AND CASUALTY CO _______________

On Appeal from the United States District Court For the Western District of Pennsylvania (D.C. No. 2-19-cv- 01382) District Judge: Honorable Robert J. Colville _______________

Submitted Under Third Circuit L.A.R. 34.1(a) March 8, 2024

Before: JORDAN, PHIPPS, and FREEMAN, Circuit Judges

(Filed March 15, 2024) _______________

OPINION _______________

JORDAN, Circuit Judge.

Rebecca Nelson appeals the District Court’s order granting the motion of State

Farm Fire and Casualty Company (“State Farm”) for summary judgment as to Nelson’s

 This disposition is not an opinion of the full court and, pursuant to I.O.P. 5.7, does not constitute binding precedent. breach of contract and bad faith claims. The District Court held that the breach of

contract claim based on State Farm’s denial of coverage for property loss was time-

barred and that the bad faith claim for the same was not supported by clear and

convincing evidence, as required under Pennsylvania law. For the reasons that follow,

we will affirm.

I. BACKGROUND1

Nelson had a homeowner’s insurance policy with State Farm. The policy

provided coverage for “accidental direct physical loss” to property. (J.A. at 87.) Design,

workmanship, construction, or maintenance defects, as well as “wet or dry rot[,]” “wear,

tear, … deterioration, … latent defect or mechanical breakdown” were explicitly not

covered under the policy.2 (J.A. at 76, 89, 91.) The policy did, however, cover losses

“resulting” from some of those exclusions, but not when “the resulting loss [was] itself”

one of the excluded forms of damage. (J.A. at 90-91.)

Further, the policy defined “occurrence” as “an accident, including exposure to

conditions, which results in … property damage[,]” and it specified that “[r]epeated or

continuous exposure to the same general conditions is considered to be one occurrence.”

(J.A. 82.) Finally, the policy provided: “No action shall be brought unless there has been

1 This background information is drawn from the District Court’s opinion granting State Farm’s motion for summary judgment and the relevant portions of the record. 2 The policy also excluded coverage for fungus/mold, including “any remediation of fungus[.]” (J.A. at 77.)

2 compliance with the policy provisions. The action must be started within one year after

the date of loss or damage.” (J.A. at 94.)

On or around April 3, 2018, Nelson noticed interior damage to the wall at the

corner of her kitchen window “that appeared to be [a] bubble.” (J.A. at 121.) She spoke

with a contractor who provided an estimate to repair the damage. She did not have it

repaired at the time. Approximately five months later, she attempted to have the same

contractor fix the damage, but he was unavailable throughout September, October, and

November of 2018.

By the time she last contacted the contractor in November of that year, Nelson

noticed additional damage. She stated that the damage “had spread in its original size[,]”

and she noticed damage to another corner of the window, as well as what she described

as “tunneling” on the inside window frame. (J.A. at 354.)

In December of 2018, Nelson asked a different contractor, Jack Giacobbi, to

perform the repairs. While inspecting the house with Giacobbi, Nelson saw similar

damage in her guest bedroom. Nelson said that Giacobbi told her a gutter had separated

from the roof and so water was not properly running off it, but was instead “channeling

into the flashing” around the windows, which caused the damage. (J.A. at 358.) Nelson

hired Giacobbi’s company, Scopewell, to install a tarp on her roof.3

3 The parties dispute whether State Farm had been informed of the damage prior to the installation of the tarp.

3 On December 17, 2018, Nelson retained a public adjuster, Brian Pfister, to submit

and manage her insurance claim for the damage. Nelson’s contract with Pfister states

that on April 3, 2018, her home sustained damages that “were caused by, and/or were the

result of water[.]” (J.A. at 401.) On December 20, Pfister reported the damage to State

Farm on Nelson’s behalf.

The following day, Nelson retained ServiceMaster Restore by All Pro

(“ServiceMaster”), a water remediation company, to inspect the property and damage at

issue. ServiceMaster concluded that a “mechanical failure or defect in the overhang of

the roof” caused the damage. (J.A. at 8.) On December 22, ServiceMaster provided

Nelson with an estimate for the water remediation, and she authorized it to perform the

work.4 ServiceMaster “located areas of drywall around the kitchen window that had

eroded severally [sic] to the point that these areas had no remaining structural integrity[]”

and “found mold and deterioration throughout the affected areas of the kitchen” and in

Nelson’s upstairs bedroom. Nelson also observed mold when the drywall had been

removed.

In either late December or early January, State Farm employee Chad Moore was

assigned to handle Nelson’s claim and to inspect the property. ServiceMaster had

completed its remediation work on January 7, 2019, and on January 9, 2019, Moore

inspected the property with Pfister present. State Farm’s claim records indicate Moore

4 The parties dispute whether State Farm approved or promised Nelson that it would pay for the water remediation work.

4 observed that: (1) “[w]ater appear[ed] to have entered into the … exterior wall from the

roof or upper … elevation allowing water to seep down through the framing”; (2) the

water infiltration had caused varying degrees of deterioration and rot to the third-floor

bedroom wall and the second-floor kitchen wall and subfloor; and (3) a tarp had been

installed on Nelson’s roof.5 (J.A. at 270.)

On January 19, 2019, State Farm sent Nelson a status letter that listed April 3,

2018, as the date of loss, quoted the Policy’s provision requiring any action to be started

within one year after the date of loss, and informed Nelson that her claim remained

pending due to the coverage investigation and that State Farm “need[ed] any information

regarding the source of water and the reason for the tarp on the roof[.]” (J.A. at 234.)

At the end of January, Pfister informed State Farm that Scopewell was the

contractor that had installed the tarp. .] Moore could not reach Scopewell until

February 27, 2019, at which point Scopewell advised Moore that it had not performed

any roof inspection. That next day, Moore told Pfister that State Farm was sending

someone to perform a roof inspection, but Pfister said the proposed inspector would not

be allowed on the property. Moore then contacted a different contractor, Restoration

Management Services (“RMS”), to conduct the roof inspection.

5 The parties dispute whether Pfister and Moore, at the time of Moore’s inspection, “knew of the source of the water infiltration and the basis for the tarp’s placement” on Nelson’s roof, or whether Pfister was to obtain and provide that information to State Farm following the inspection. (J.A. at 9.)

5 On March 1, 2019, State Farm sent Nelson another status letter which again

identified April 3, 2018, as the date of loss and quoted the same contractual limitation

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Rebecca Nelson v. State Farm Fire and Casualty Co, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rebecca-nelson-v-state-farm-fire-and-casualty-co-ca3-2024.