In Garvey v. State Farm Fire & Casualty Co. (1989) 48 Cal.3d 395, the court again faced a claim for subsidence damage and an insurance policy that excluded coverage for losses caused by "'settling, cracking, shrinkage, bulging or expansion of pavement, patios, foundations, walls, floors, roofs or ceilings . . . .'" ( Id. at p. 407.) In 1978, the homeowners noticed that an addition to the house had begun to pull away from the main structure, and other damages were appearing on a deck and garden wall. ( Id. at p. 400.) As in Sabella, contractor negligence was alleged to be a contributing factor of the damages. (Gravey, supra, 48 Cal.3d at p. 400.) In particular, the plaintiff's expert testified that, because footings had not been made deep enough, when the ground began to settle and creep downhill, "'the footing just went along for the ride.'" ( Id. at p. 412.) The high court concluded the case was controlled by Sabella, and the question of which cause -- earth movement or negligent construction -- was the efficient proximate cause should have been decided by the jury. (Garvey, at pp. 412-413.)