The insured’s claim that the insurer breached its duty to advise on coverage offered by the policy failed. Piatt Lake Bible Conference Ass’n v. Church Mutual Ins. Co., 2026 U.S. App. LEXIS 1095 (6th Cir. Jan. 13, 2026).

Piatt Lake Bible Conference Association held a blanket insurance policy with Church Mutual insuring several buildings up to $3.5 million with a $100,000 sub-limit for code-compliance costs. One of the insured buildings was the “Miracle Building” which was built in 1973 as a two-story multi-purpose log building. Due to its age, the Miracle Building lacked many new features required for modern code compliance.

Piatt Lake alleged that before securing the policy, Church Mutual made various statements which erroneously led Piatt Lake to believe that it would be covered to fully rebuild the Miracle Building, including all code-compliance costs, regardless of the policy’s $100,000 code compliance cap.

First, a Church Mutual brochure stated that church Mutual would provide “on-Sit Risk and Insurance Needs Analysis” The brochure stated, “The information we gather forms the basis of your customised proposal.”

Second, in 2014, a Piatt Lake board member communicated with a Church Mutual agent over the phone and by email. From these communications, the board member understood that the policy covered the cost of replacing what Piatt Lake actually had or the cost to reproduce or reconstruct a building the same way as it was.

Third, in 2019, another Piatt Lake board member met with a Church Mutual agent to review the policy and make a site tour of the building. From this meeting, the board member understood Piatt Lake was fully covered, meaning if something happed to one of the buildings, Piatt Lake would be fully covered to replace the building.

In March 2020, the Miracle Building collapsed due to snow and ice. Piatt Lake submitted a claim to Church Mutual. Church Mutual determined that the Miracle Building’s total replacement value was approximately $2.3 million.

Piatt Lake hired a contractor who estimated it would cost $3.7 million to rebuild – $1.4 million more than Church Mutual’s estimate replacement cost coverage. The $3.7 estimate included a new building layout, design, and code-compliance upgrades needed to pass modern inspection standards. Piatt Lake alleged that the costs exceeding Church Mutual’s $2.3 million coverage amount – $1.4 million – consisted entirely of code-compliance costs. Church Mutual refused to cover the code-compliance costs beyond the $100,000 policy cap.

Piatt Lake sued Church Mutual seeking $1.3 million. The federal district court granted summary judgment to Church Mutual because Piatt Lake failed to show both a duty was owed and reliance for its various fraud, misrepresentation and promissory estoppel claims. Piatt Lake failed to demonstrate (1) an ambiguous request was made that required a clarification, or (2) an inquiry was made that could require advise and the agent, though he need not, give advise that was inaccurate. Piatt Lake appealed.

The Sixth Circuit affirmed. Under Michigan law, when the parties had a contract, tort claims could only proceed if tortious conduct existed independent of the contract. Independent tortious conduct required the plaintiff to allege a violation of a duty separate and distinct from the underlying contract obligation. Piatt Lake argued Church Mutual owed a separate and distinct duty to advise it on the adequacy of its coverage. Piatt Lake argued the brochure and communications with Church Mutual demonstrated a special relationship. The Sixth Circuit disagreed.

First, there was no indication the Church Mutual brochure was provided in response to a request or inquiry. Next, the 2014 exchange contained neither an ambiguous request nor inaccurate advice. Piatt Lake agreed the agent spoke about the blanket nature of the policy coverage, not the code-compliance costs. Similarly, the 2019 exchange contained no inaccurate advice or ambiguous request. Piatt Lake failed to show that a special relationship was created. There was no separate and distance duty to advise and the fraud claims failed.

Piatt Lake’s claims also failed because it could not show that it reasonably relied on Church Mutual’s alleged representation that it would cover code-compliance costs exceeding the $100,000 policy limit.

Further, the unambiguous undisputed terms of the policy limited code-compliance coverage to $100,000. Any representation suggesting that code-compliance coverage exceeded $100,000 directly contradicted the unambiguous language, so reliance on any such representation would be unreasonable.

Finally, Piatt Lake could not show that it actually relied on any of Church Mutual’s alleged misconduct.

Therefore, the district court’s granting of summary judgment to Church Mutual was affirmed.