Findlay v. United Pacific Ins. Co
In Findlay v. United Pacific Ins. Co. (1996) 129 Wash.2d 368 917 P.2d 116, 119, the Supreme Court of Washington ruled that a weather conditions clause did not violate that state's proximate cause rule.
In Findlay, the insureds' home was damaged when the slope behind it failed.
The parties agreed that the efficient proximate cause of the loss was wind and rain.
The court based its ruling on a finding that loss caused by weather conditions was excluded from the policy, stating that "the policy excludes loss caused by weather conditions, but then adds back or restores coverage for losses caused by weather which does not occur in concert with one of the policy's other stated exclusions." (Id. at p. 379 917 P.2d at pp. 121-122.)