Cheviot Vista Homeowners Association v. State Farm & Casualty Co.

Cheviot Vista Homeowners Association (Homeowners Association) appeals from the judgment entered after the trial court granted summary judgment in favor of State Farm Fire and Casualty Company (State Farm) in the Homeowners Association’s action concerning the adjustment of its property damage losses from the 1994 Northridge earthquake. We affirm.

FACTUAL AND PROCEDURAL BACKGROUND

1. The Homeowners Association’s Earthquake Coverage and Northridge Earthquake Damage Claim

Prior to the January 17, 1994 Northridge earthquake, State Farm issued a condominium association policy with an endorsement for earthquake coverage to the Homeowners Association insuring a 22-unit condominium building located at 3231 Cheviot Vista Place, Los Angeles. The policy in effect from March 14, 1993, to March 14, 1994, had a limit of coverage for damage caused by earthquake of $2,612,398, with a 10 percent deductible ($261,239).

The condominium complex was damaged by the Northridge earthquake. By January 25, 1994, the Homeowners Association submitted a claim to State Farm for damage to the building and common areas of the complex, as well as to at least some of the individual units. On January…