In Gillis v. Sun Ins. Office, Ltd. (1965) 238 Cal. App. 2d 408, the culprit was weather. A windstorm uplifted a gangway, sending it crashing back down on the insured's docking facility causing the dock to sink into the water. The insurance policy "insured the said docking facility against loss or damage caused by wind," and excluded coverage for "loss occurring to the docking facility caused by water or damage from, contributed to or aggravated by surface water or waves." The insurance company argued the water and waves contributed to and aggravated the damage and thus it was not liable to provide coverage under the policy. The appellate court disagreed. It found the wind was the efficient proximate cause of the loss and the contribution and aggravation of damages from the water did not defeat recovery. Gillis v. Sun Ins. Office, Ltd., supra, 238 Cal. App. 2d at page 424.