Lincoln Fountain Villas Homeowners Ass'n v. State Farm Fire & Casualty Insurance

Lincoln Fountain Villas Homeowners Association (Homeowners Association) appeals from the judgment entered after the trial court granted summary judgment in favor of State Farm Fire & Casualty Insurance Company (State Farm) in the Homeowners Association’s action concerning the adjustment of its property damage losses from the 1994 Northridge earthquake. The Homeowners Association contends evidence a 2001 cost-of-repair estimate was three times larger than the estimate prepared by State Farm in 1994 created triable issues of material fact as to whether State Farm had failed to thoroughly and objectively investigate and evaluate its claim, failed to properly adjust its claim and failed to pay the full policy benefits to which the Homeowners Association was entitled. The Homeowners Association also contends it demonstrated triable issues of fact regarding the propriety of State Farm’s method of calculating its loss in 1994. 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…