Smith v. Nationwide Mutual Insurance Company et al.

Plaintiff Smith owned a Texas home insured by Nationwide. After a 2016 hailstorm, Nationwide's adjuster confirmed damage to some shingles but refused a full roof replacement, offering only partial repair. Smith argued the policy required "matching" of materials and that a patchwork repair would reduce property value. He sued for breach of contract and insurance bad faith. On September 27, 2018, the U.S. District Court for the Northern District of Texas evaluated cross-motions for summary judgment. The court found genuine factual disputes over whether the damage constituted direct physical loss to the entire roof and whether Nationwide's investigation was reasonable, allowing the case to move forward.

The court denied Nationwide’s motion for summary judgment on the breach of contract and bad faith claims, ruling that genuine issues of material fact existed and allowing the case to proceed.

Whether the homeowner’s insurance policy mandated that undamaged roofing sections be replaced to match repaired areas, and whether Nationwide’s partial denial of the claim constituted bad faith.

The ruling reinforced insurers’ duty to consider material matching in property claims and provided policyholders in Texas with a stronger basis to challenge partial repair denials, influencing claim handling practices across the industry.