In November 2025, the Twelfth District Court of Appeals issued its decision in Leonard v. State Farm Fire & Casualty Co., affirming dismissal of the policyholder’s claims arising from a disputed roof claim. Although the case involved legal arguments about appraisal, code compliance, and coverage, the true story is something far simpler—and far more common. The insured’s case collapsed not because the facts were unfavorable, but because it was never properly built in the first place.
And this is precisely where a qualified public adjuster could have changed the trajectory entirely.
A Roof Claim That Became a Legal Maze
After a June 2022 windstorm damaged portions of the insured’s roof, State Farm wrote an estimate to replace 22 shingles and a small section of decking. The insured’s contractor, by contrast, produced a full roof replacement estimate over $50,000, citing spaced decking and shingle-discontinuation issues.
When negotiations stalled, the insured—through counsel—tried to force appraisal. The trial court denied the motion, finding the dispute wasn’t about “amount of loss” but about coverage and legal interpretation, issues expressly barred from appraisal. The attorney then attempted to recast the dispute as one of mandatory code compliance under the Residential Code of Ohio (RCO). But this argument, too, faltered because:
1. The legal theory was improperly framed;
2. The evidence was insufficient; and
3. The most critical document—the actual insurance policy—was never even filed with the court.
Predictably, the court granted summary judgment for State Farm.
Where the Attorney’s Strategy Went Off Course
The attorney tried to argue the roof had to be replaced because undamaged sections could not be lawfully repaired under the RCO. But the RCO issue wasn’t about wholesale replacement of undamaged roofing—it was an issue of repairability, which is a fundamentally factual determination. That requires:
- A properly documented causation analysis,
- A detailed inspection report,
- Photographic evidence supporting decking and shingle conditions,
- A code-based narrative connecting each required step of replacement to specific, enforceable provisions.
None of that was built into the record. The contractor’s estimate was not supported with field-specific documentation, and the attorney attempted to argue replacement based on misapplied code language relating to undamaged building components. The court correctly identified that the case did not turn on “matching” or “line of sight”—it turned on what the policy covered and whether the contractor’s repair prohibitions were factually substantiated. They were not.
Furthermore, by failing to introduce the actual policy into evidence, the plaintiff could not prove a breach of contract or enforce the Option OL ordinance-and-law coverage he repeatedly referenced. The absence of the policy alone doomed the breach-of-contract count.
Where a Public Adjuster Could Have Changed the Outcome
- Proper Development of the Causation and Repairability Record
Before any attorney becomes involved, a public adjuster establishes the foundational elements required for a claim:
- Condition of the roof before and after the storm,
- Precise shingle discontinuation analysis (including manufacturer verification and sample testing),
- Decking spacing measured and documented to code,
- Scope-of-loss diagrams linking each repair step to its code basis,
- A complete comparative estimate showing the carrier’s repair plan is not feasible.
A public adjuster would not have allowed the dispute to be framed as:
“Does the policy require replacement of undamaged roofing?”
Instead, the correct framing would have been:
“Is the damaged area repairable without violating building code, manufacturer installation requirements, or the policy’s promise of like-kind-and-quality replacement?”
That is a question grounded in field facts—not legal theory.
- Avoiding the Appraisal Misstep
Public adjusters understand the distinction between:
- Amount of loss (appraisal), and
- Coverage/legal interpretation (not appraisal).
Here, the attorney attempted to shoehorn a code-compliance coverage argument into the appraisal process. The court correctly rejected it because the policy’s appraisal clause explicitly bars legal and coverage questions from appraisal.
A public adjuster would have avoided this procedural detour and instead built a factual dispute over repair feasibility—something that is within appraisal jurisdiction.
- Ensuring the Policy is in the Record
This case was lost in large part because the policyholder did not introduce the policy into evidence. Every coverage argument, every Option OL reference, and every claim of breach depended on the policy language—none of which the court was permitted to consider because the attorney never filed it.
A public adjuster manages and organizes claim documentation, and the policy is the first, most critical piece of evidence.
- Constructing a Code-Compliant Narrative
Rather than citing broad, misapplied RCO provisions, a public adjuster would have:
- Identified the exact building code sections implicated;
- Documented how spaced decking affects fastener pull-through, uplift resistance, and shingle adhesion;
- Demonstrated the physical impossibility of performing repairs consistent with manufacturer installation requirements;
- Connected each required action to the policy’s Loss Settlement, Loss Payment, and Ordinance & Law provisions.
This creates a clear, compelling, and factually anchored claim presentation—one the court could rely on, and one the carrier must meaningfully respond to.
The Real Takeaway: Claims Don’t Fail Because Homeowners Are Wrong—They Fail Because They Are Unprepared
Leonard v. State Farm is not a case about shingles, codes, or matching. It is a case about structuring a claim—and how quickly the results unravel when the foundational components are missing or mishandled.
Had a public adjuster been involved:
- The appraisal demand would have been framed accurately,
- The repairability argument would have been fully developed,
- The factual record would have supported the contractor’s position,
- The policy would have been introduced, and
- The attorney would have had a properly documented claim to litigate.
Instead, the insured lost on every issue—not because he was wrong, but because his case was never built on the proper merits.
Conclusion: Public Adjusters Don’t Just Estimate Losses—They Build Recoverable Claims
This case reinforces a fundamental truth: The best legal arguments in the world cannot overcome an underdeveloped record. Public adjusters fill that gap. They protect policyholders from procedural pitfalls, develop the facts essential to proving repairability, and ensure the claim is positioned correctly from the start.
When the stakes are high, and when code issues or complex repairability questions arise, bringing in a public adjuster early is not just beneficial—it is essential.
Disclaimer: The employees of Green Public Insurance Adjusting are not attorneys and do not provide legal advice. The information in this blog post is for general educational and informational purposes only and should not be interpreted as legal guidance. Readers should consult with a qualified attorney for advice regarding any legal matters or questions related to their specific situation.
