Priscilla Croxdale v. Travelers Home and Marine Ins.
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Case Summary
Disposition
Affirmed
The case concerns whether an Iowa homeowners-insurance policy excludes coverage for all water damage when a leak lasts more than fourteen days or only for damage occurring after the initial fourteen-day period. The Eighth Circuit interpreted the policy to exclude all losses once the leak surpassed two weeks and therefore affirmed summary judgment for Travelers, also rejecting the insureds’ bad-faith claim.
Circuit Split Identified
Legal Issue
Whether a homeowners-insurance clause excluding losses caused by water "that occurs over a period of weeks, months, or years" bars coverage for all damage once a leak lasts longer than fourteen days, or only for damage that occurs after the initial fourteen-day period.
Circuit Positions
Leak lasting more than fourteen days triggers the exclusion for all losses, even those incurred during the first fourteen days.
Exclusion applies only to losses that occur after the leak has continued for fourteen days; damage during the first fourteen days remains covered.
Conflict Summary
The Eighth Circuit holds that once a leak exceeds fourteen days, the exclusion eliminates coverage for every loss caused by that leak, including damage that occurred during the first fourteen days. The Tenth Circuit (Wheeler v. Allstate Ins. Co.) concluded that the exclusion bars only the losses that occur after the leak has exceeded fourteen days, leaving earlier damage covered.