Give Me a Break: A Mobile Home that Can’t Be Used or Moved is a Total Loss

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In Patricia Crisco, et al. v. Foremost Insurance Company Grand Rapids, Michigan, et al., No. C 19-07320 WHA, USDC (December 4, 2020) victims of a wild fire sued their insurer claiming a total loss to their mobile homes because the park infrastructure was destroyed by the fire and the homes were not liveable even if their walls were intact.


Catastrophes, like the wild fire that destroyed the mobile home park where Plaintiffs’ homes sat, result in strange decisions by insurers and courts. In this case, the mobile homes in question were not destroyed by fire but they were destroyed by the wild fire that eliminated the infrastructure necessary to make them a home. Standing on a technicality, and even trying to use a California Supreme Court decision, Hughes v. Potomac Ins. Co. of District of Columbia, 199 Cal. App. 2d 239, 248-49 (1962) which supported the plaintiffs, not Foremost, because it held a house on the edge of a cliff still intact was totally destroyed, was unwise.