The District Court for the Middle District of Florida ruled that an insurer had to cover the costs to tear out and replace part of an insured's home as part of replacing the insured's plumbing. The case is Floyd v. Geovera Specialty Ins. Co., 2020 U.S. Dist. LEXIS 35346 (M.D. Fla. 2020). 

David Floyd purchased an all-risks property policy from GeoVera for his home. During the policy period, the master bathroom toilet overflowed and caused extensive water damage. In order to stem the flow of water, Floyd removed the toilet and snaked the drain line. When the drain snake was removed, it brought several plant roots with it, indicating a bigger problem with the underground plumbing in Floyd's home. Floyd timely notified GeoVera of the damage. 

GeoVera sent an adjuster to investigate Floyd's claim. Floyd explained the actions he had taken to mitigate the overflowing toilet, but the adjuster declined to investigate the plumbing. GeoVera accepted and paid Floyd's claim without dispute. Floyd, however, claimed the payment was insufficient to cover the repair costs for the water damage.