State Farm just lost a Louisiana appeal that throws its burst-pipe denial back into play – and puts third-party winterization squarely on insurers’ radar.
The Louisiana Second Circuit Court of Appeal on May 20, 2026, reversed a trial court ruling that had handed State Farm Fire and Casualty Company a summary judgment win in a freeze-damage coverage fight. The message to carriers writing property risk in cold-snap territory: when a policyholder leans on someone else's winterization, whether that counts as reasonable care is a question for trial, not a motion.
The case began in December 2022. William Bennett bought a vacant home at 1300 2nd Street North in Monroe, Louisiana, listed by Sweet Olive Homes, LLC, with Rob White as the agent. Two weeks later, Bennett bought a State Farm policy. The next day, he transferred the property to his company, Bennett Properties of North Louisiana, LLC.
Shortly after, a freeze warning hit Monroe and the pipes burst. A City of West Monroe worker, Jarrett Wilson, was sent out after the city's system flagged a pressure drop. He could hear water running inside the home. The valve between the main and the meter was broken, so he had to fix it before he could shut the water off.
Bennett filed a claim. State Farm denied it on February 24, 2023, pointing to a "Losses Not Insured" clause that bars coverage for freeze-related plumbing damage in a vacant or unoccupied home unless the insured used reasonable care to either maintain heat in the building or shut off the water supply and drain the system.
Bennett's argument was simple: the home had been winterized before he ever owned it, and placards throughout the house said so. The notices warned anyone in the property not to turn on the water or reconnect electricity to the hot water heater, told them to avoid the sinks and toilets, and stated that the water had been shut off to prevent freeze damage. They were dated September 22, 2022, and signed by Sweet Olive Homes LLC. City utility records showed no water usage at the property from August 2022 to December 18, 2022.
State Farm's pitch at summary judgment was clean. No heat in the home. A burst that proved the system was still pressurized or never properly drained. Exclusion applies. Coverage off.
The appellate court did not buy it – at least not without a trial. The judges pointed out that Bennett relied on the placards, that the City's water valves are locked so a homeowner cannot independently check the meter, and that turning the taps to test would itself risk a flood if the water turned out to be live.
The court also said State Farm had not established that a policyholder's reliance on a third party to winterize would void the policy. The judges drew on State Farm Fire & Cas. Co. v. Dean Flores Real Est., LLC, 20-1087 (La. App. 1 Cir. 5/12/21), 326 So. 3d 292 – a case where State Farm itself sued a third-party winterizer after paying out on a similar burst-pipe loss. In both, a State Farm policyholder leaned on someone else to winterize. In both, the pipes burst. On those grounds, the court ruled Bennett's reliance on the placards was not an issue that could be decided on summary judgment.
The court was more split on the other rulings. It affirmed dismissing Bennett in his individual capacity – once he transferred the home to his LLC on December 16, 2022, the LLC became the only proper plaintiff. But it reversed the exceptions of no right of action against "Bennett Properties, LLC," saying those should have been treated as moot once the petition was amended to name Bennett Properties of North Louisiana, LLC, as the correct plaintiff.
For carriers, the practical lesson sits in that one ruling on third-party reliance. The Second Circuit did not strike the freeze exclusion. It said whether a policyholder's reliance on a contractor's winterization counts as reasonable care is a fact question – and carriers need more than a vacant home and a burst pipe to clear it on summary judgment.
The case is reversed in part and affirmed in part, with costs split equally between the parties. An application for rehearing may be filed within the time allowed by Louisiana Code of Civil Procedure Article 2166.
