Does an incomplete roofing system qualify as a roof under homeowner's insurance policies? Poulsen v. Farmers Insurance Exchange Explained

The Utah Court of Appeals addressed a fundamental question of insurance coverage interpretation in Poulsen v. Farmers Insurance Exchange, examining whether an incomplete roofing system constitutes a “roof” under a homeowner’s insurance policy.

Background and Facts

The Poulsens were in the process of replacing their roof shingles when a severe windstorm struck. At the time of the storm, they had removed the old shingles and installed new ice and water shield and underlayment over the plywood decking, but had not yet installed the new shingles. The storm winds tore off the underlayment, allowing rain to penetrate the house and cause significant damage. Farmers Insurance denied their claim under the policy’s limited water coverage provision, which only covered water damage when water entered through an opening in the roof caused by specified perils, including windstorms.

Key Legal Issues

The central issue was whether the combination of plywood, ice and water shield, and underlayment—without shingles—constituted a “roof” within the meaning of the insurance policy. The Poulsens argued that any structure covering the top of the walls qualified as a roof, regardless of its state of completion. Farmers contended that the incomplete system was merely a temporary covering excluded from coverage.

Court’s Analysis and Holding

Despite Utah’s principle of construing insurance policies liberally in favor of coverage, the court held that the word “roof” was not fairly susceptible to different interpretations that would include incomplete roofing systems. The court emphasized that the Poulsens’ own expert testified that “underlayment without shingles is not a complete roofing system” and that “it takes both components to make the roofing system resistant to high wind, snow, ice and water.” The court concluded that component parts falling short of a complete roofing system could not reasonably be considered a “roof” under the policy’s commonly understood meaning.

Practice Implications

This decision demonstrates that even Utah’s pro-coverage interpretive principles have limits when policy terms have clear, commonly understood meanings. Practitioners should recognize that incomplete structures or systems may not qualify for coverage under policies that require specific completed elements, regardless of the insured’s reasonable expectations.