## Facts

- Jay and Deanna Clasing operated a hog-confinement business known as Jade Farms, with four swine barns monitored by an alarm system connected to the business office.
- The office previously suffered a fire and was undergoing repairs; during the repair period, the barns’ alarm system was not functioning.
- An ice storm caused a power outage and a malfunction affecting ventilation in one of the barns.
- A large number of hogs died in the barn without any alarm warning due to the inoperable system.
- The Clasings submitted an insurance claim to State Farm Fire & Casualty Company for the livestock loss.
- State Farm denied the claim based on a policy exclusion for “loss of livestock by suffocation.”
- In a recorded statement taken by State Farm, Jay Clasing answered “Yes” to the question, “So there’s really no questions as to the hogs suffocated?”
- The Clasings sued State Farm for breach of contract, asserting the hogs did not die from “suffocation” within the meaning of the exclusion, but from conditions tied to inadequate ventilation after the office fire and repairs.
- The Clasings supported their position with a veterinarian’s affidavit opining the hogs likely died from overheating.
- State Farm moved for summary judgment; the trial court granted the motion, concluding that although the ice storm was a legal cause of the loss, the hogs’ deaths were directly and immediately caused by suffocation, triggering the exclusion.

## Issues

1. Whether the summary-judgment record established as a matter of law that the hog deaths were a “loss of livestock by suffocation” excluded from coverage.
2. Whether conflicting evidence on causation (including the recorded statement and the veterinarian affidavit) created a genuine dispute of material fact requiring trial.

## Decision

- The trial court granted summary judgment for State Farm, holding the suffocation exclusion barred coverage.
- The Iowa Court of Appeals reversed and remanded (decision without published opinion), setting aside the grant of summary judgment.

## Legal Principles

- Summary judgment is improper when the record permits competing reasonable inferences on a material fact, including the cause and characterization of an insured loss.
- In insurance coverage disputes, the insurer bears the burden to show an exclusion applies, and exclusions are generally construed narrowly under Iowa law.
- A lay insured’s recorded description of a loss (such as agreeing with an adjuster’s phrasing) may be evidence, but it is not necessarily conclusive where other admissible evidence supports a different account.
- When coverage turns on how a loss should be classified under policy language (here, whether the deaths were “by suffocation”), that classification may present a fact question when supported by conflicting evidence.

## Conclusion

Because the record contained conflicting evidence about how and why the hogs died—including the insured’s recorded statement and a veterinarian’s opinion that the hogs likely died from overheating—the appellate court reversed the summary judgment for State Farm and remanded for further proceedings on whether the suffocation exclusion applied.


Clasing v. State Farm Fire & Casualty Company, 771 N.W.2d 652 (2009)