Applyng California law, the Ninth Circuit affirmed the district court’s finding that water damage caused by a leaking pipe over time was not covered under the insured’s homeowners’ policy. Mojica v. State Farm General Ins. Co., 2025 U.S. App. LEXIS 32405 (9th Cir. Dec. 11, 2025).

A small hole, slightly larger than a pen tip in size, developed in a pressurized hot water pipe. The resulting leak lasted for nearly six days and released enough water to saturate and ruin all the subflooring and flooring in the insureds’ home.

The insureds’ policy was issued by State Farm. Coverage A provided coverage for loss to their dwelling unless specifically excluded. Under Coverage B, loss to personal property was covered only if caused by a covered peril, including an abrupt and accidental discharge or overflow of water. State Farm denied the insureds’ claims under both Coverage A and Coverage B. The insureds sued and the district court granted summary judgment to State Farm.

The Ninth Circuit found that under Coverage A, the district court correctly determined that the damage to the pipe was excluded. Exclusion 1.f excluded damage caused by “wear, tear . . . or deterioration.” Exclusion 1 g. barred coverage for damage caused by “corrosion, electroklysis or rust.” State Farm’s motion was suppored with evidence that the plumber who replaced the damaged section of pipe stated that the “pipe most likely failed due to wear, tear, deterioration and or corrosion.”

Water damage was also excluded under Coverage A under Exclusion 3.c.9 which excluded damage “that is caused by . . . water, meaning . . . seepage or leakage of water . . . that occurs or develops over a period of time . . . and is . . . continuous . . . and from a . . . plumbing system.” Given the multi-day duration of the leak, the small size of the hole, and the widespread nature of the damage, the exclusion applied.

For the same reasons, the district court did not err in granting summary judgment on the insureds’ personal-property claims under Coverage B. As a matter of law, the insureds could not show that their losses were caused by an “abrupt and accidental discharge or overflow of water.”