Webster's Ninth New Collegiate Dictionary defines a roof as "the cover of a building." In this case, the plastic sheeting served as the "cover of a building" (albeit temporary) while it was being remodeled.

The same dictionary also indicates that the "material used for a roof" can constitute a roof. In this case the plastic was the material being used as a cover.

Even though some courts have held that a temporary roof is a roof within the meaning of the windstorm peril (see case referenced in the next paragraph), insurance companies have not yet restricted the policy definition to exclude temporary materials. As the policy does not define "roof," we believe that the plastic sheeting falls within the accepted meaning of the word; and that coverage should be afforded for such loss.

For example, in the case of Homestead Fire Insurance Co. v. De Witt, 245 P.2d 92 (1952), the supreme court of Oklahoma ruled that a canvas covering constituted a roof that was opened by the wind, bringing the loss within the policy's coverage.

However, in Diep v. California Fair Plan Ass'n., 19 Cal.Rptr.2d 591 (Cal.App. 2 Dist., 1993) a court of appeals held that a plastic covering was not tantamount to a roof, stating that the word "roof" as used in the policy did not include a temporary cover of plastic sheeting and that the opening to the interior of the building was caused by workman, and not by wind.

For additional insight into this type of claim, see Commercial Property—Water Damage—Shingles Removed by Workmen.