No coverage for childcare injuries under homeowner policy, IA court holds

Iowa case law summary by Attorney Richard Clem: insurance.

State Farm Fire & Cas. Co. v. Tim Mrzlak and Dawn Mrzlak. IA insurance

In this appeal from Grundy County, the Iowa Court of Appeals affirmed the trial court's holding that the childcare and business exclusions of a homeowner's policy. The appeals court held that the evidence supported the trial court's finding, and that there was no reasonable expectation of coverage under the circumstances.

No. 13-1552 (Iowa Ct. App. Sep. 23, 2015)

Please see the original opinion for the court's exact language.


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Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).

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