A Rhode Island appellate court ruled that corrosion damage inside the fuse box of a man's car is not covered by the comprehensive part of the man's auto policy.  The case is Cummings v. Phoenix Ins. Co., 2016 R.I. Super. LEXIS 18 (R.I. Super. 2016). Please note that the originally filed suit misidentified Phoenix Insurance Company (Phoenix) as Travelers Indemnity Company of Connecticut. For the sake of clarity, this analysis will use Phoenix throughout.

Peter Cummings took his car, a BMW 740i, to Advanced Autobody (Advanced) for repairs following an auto collision. His auto insurer, Phoenix, paid the original repair estimate and two subsequent supplemental estimates to Advanced under the collision coverage in Cummings' policy. The vehicle was stored at Advanced while repairs were made over a period of three months. 

When Cummings began having problems with his car post-repairs, he took it to a BMW dealership rather than Advanced. A technician opened the electrical box under the hood of the vehicle, Cummings discovered standing water and corroded wires inside the box. He filed an additional claim for this damage, and another one for damage to the paint job. Phoenix denied these claims, citing pre-existing damages and normal wear-and-tear. Cummings filed suit for breach of contract, breach of good faith, and quantum meruit, which means Phoenix had received "an unearned benefit" at Cummings' expense.