A Texas homeowner's insurer is going after water heater manufacturer A.O. Smith, saying a faulty unit flooded an insured home and cost the carrier more than $172,000.
The subrogation suit was filed on April 23, 2026, in the US District Court for the Eastern District of Texas, Tyler Division. The plaintiff, Texas Farmers Insurance Company, is stepping into the shoes of its insureds, Roderick and Renee Smith, whose home on Swinging Bridge Road in Longview, Texas, sprang a leak on May 14, 2024.
The damage, according to the filing, spread through the structure and contents of the home, and pushed the Smiths into additional living expenses while the property was being repaired. Farmers says its homeowners policy was in force at the time, and the carrier paid out $172,089.76 on the claim, including the deductible the Smiths themselves fronted. That payment, the filing says, is what gives Farmers the right to chase the manufacturer.
So what went wrong? According to the complaint, the culprit was the lower heating element of a 2021 A.O. Smith water heater - model ENT-50-130 - installed at the home. Farmers alleges the element was defectively designed or manufactured, and that the unit failed well within its expected useful life and within the manufacturer's own six-year warranty. The heater was just three years old.
The filing also takes pains to head off the usual defenses. The insureds, it says, did nothing to the heater - no modifications, no alterations, no abuse, no signs of bad installation. It was, in the carrier's telling, a product that simply failed on its own.
Farmers is pursuing three theories. First, negligence - that A.O. Smith didn't take reasonable care in designing, testing, and marketing the heater, and didn't give consumers clear enough warnings or instructions. Second, strict product liability - covering design defects, manufacturing defects, component defects, and a failure to warn, with Farmers alleging a safer alternative design was available and economically viable when the unit was built. And third, breach of warranty - both the express six-year manufacturer's warranty and the implied warranties of merchantability and fitness for a particular purpose under the Uniform Commercial Code and Texas law.
For claims teams and subrogation professionals, the filing is a familiar but useful reminder. Water heater failures are a recurring source of homeowners losses, and carriers that move quickly to preserve the failed unit and lock in cause-and-origin findings tend to be the ones best positioned to recover from manufacturers down the line. Pairing strict liability claims with UCC warranty theories, as Farmers has done here, is a common carrier approach in product defect subrogation.
The allegations have not been tested in court. A.O. Smith has not yet responded, and no court has ruled on the merits.
