The insurer was awarded summary judgment, in part, after paying a portion of the insured’s claim for hurricane damage. Taylor v. State Farm Fire & Cas. Co., 2025 U.S. Dist. LEXIS 231406 (S.D. Ala. Nov. 24, 2025).

The Taylors’ home was damaged by Hurricane Sally. They submitted a claim under their homeowners’ policy to State Farm. They reported trees collapsing onto the house and blocking the front door, broken windows and doors, water damage and the roof collapsing in certain rooms of the house.

State Farm conducted several inspections. Over time, State Farm made payments in the amount of $522,873.22. This included $4,636.50 for an antique dresser that the Taylors submitted was worth $17,600. State Farm asked the Taylors for additional information to finish its evaluation and determine what additional amounts were owed.

The Taylors moved to a new residence during State Farm’s handling of their claim. State Farm informed the Taylors that they would not make additional payments because the Taylors no longer had an insurable interest in the property once it was sold. Replacement cost benefits were not owed since the property was sold without making any repairs.

The Taylors sued State Farm for breach of contract in failing to pay the full and correct amount of benefits owed under the policy and for bad faith. State Farm moved for summary judgment.

State Farm argued that the Taylors did not perform their duties under the policy for Coverage A because they did not complete the repairs or replacements on the property within two years of the damage to the swelling as required. The Taylors argued that since they replaced their damaged home with a new home in another location, they were still entitled to replacement cost value (RCV).

The policy stated that RCV would be paid when the insured “completed the actual repair or replacement of the damaged part of the property within two years after the date of loss.” The Taylors contended that because this provision did not state that replacement must be on the premises identified in the Declarations, the policy was ambiguous. Considering the entirety of the policy, the court disagreed. Any RCV benefits only accrued when repairs and replacements were completed on the property. The Taylors did not make any repairs or replacements on the property within the two-year time frame so they were not entitled to receive RCV. Summary judgment was granted to State Farm on this claim.

The court denied State Farm’s motion regarding Coverage B for the antique dresser. There were genuine issue of material fact as to the market value of the dresser.

Finally, the court granted State Farm’s motion on the bad faith claim. State Farm investigated the claim, continuously updated the Taylors on the status of their claim and when the Taylors did not respond to their letters, State Farm continued pursuing the claim and attempting to get in touch with the Taylors.