In Poulsen v. Farmers Insurance Exchange, 26 UT App. 170 (2016) the court found that Farmers' homeowners policy did not provide coverage for water intrusion from a wind storm when the water entered into the house through a partially completed roof. The roof contained only roofing components that were in place at the time of the storm and was not a roof.
The Montana Supreme Court in Parker v. Safeco Ins. Co. of America, 384 Mont. 125, 2016 MT 173, 376 P.3d 114 (2016), held that an earth movement exclusion was not limited solely to damages caused by soil movement. The Court found that earth movement included damage caused by a falling boulder. The Court noted that the insurance policy in question included as examples of earth movement both landslides and lava flows but did not mention soil; the policy did not provide a basis for separating rock and soil when construing the exclusion. The Court found that nothing in the language of the earth movement exclusion indicated that there was any basis for separating rock from soil when considering earth movement. A common understanding of the term landslide in the context of the exclusion could include a large boulder that came down the hill and crashed into the insured's cabin. Because a common understanding of the term landslide in the context of the exclusion would include the large boulder that came down the hill and crashed into the insured's cabin, the policy excluded coverage for the loss.