The Supreme Court of Iowa agreed the city had no coverage for damage to its property after a squirrel triggered an electrical arc. City of W. Liberty v. Employers Mut. Cas. Co., 2019 Iowa Sup. LEXIS 6 (Feb. 1, 2019). 

    A squirrel climbed on to an electrical transformer at West Liberty's power plant. While touching a ground steel frame, the squirrel came into contact with a bare cable clamp that carried 7200 volts of electricity. This contact created a conductive path between the clamp and the grounded frame. Arcing resulted. The squirrel was killed and the arcing caused $213,524 worth of damage to West Liberty's transformer and other equipment. 

    West Liberty notified its all-risk insurer, Employer's Mutual Casualty Company (EMC) of the loss. Coverage was denied based upon an "Electrical Currents" exclusion in the policy. The policy excluded coverage for "loss caused by arcing or by electrical currents other than lightning." 

    West Liberty filed suit. Cross motions for summary judgment were filed. The trial court granted EMC's motion and denied West Liberty's motion. The court held that it could not decide that the squirrel's actions were a cause of damages because the squirrel did not actually do anything to cause damages. Instead, it merely touched things it should not have touched. The arc caused all of the damages. The court of appeals affirmed, relying upon the electrical currents exclusion. 

    The Iowa Supreme Court affirmed. The language of the exclusion was straight-forward. If arcing caused the loss, the loss was excluded. West Liberty, however, argued the squirrel was the efficient proximate cause of the loss. The efficient proximate cause doctrine applied when two or more causes, at least one covered by the policy and at least one excluded, contributed to a loss. 

   This case, however, was not one of two independent causes, one of which was covered and one excluded. The squirrel did not independently contribute to the loss, i.e., other than through the arcing. Therefore, the decision of the court of appeals was affirmed.