Villella v. Public Employees Mutual Insurance Co
In Villella v. Public Employees Mutual Insurance Co., 106 Wn.2d 806, 815, 725 P.2d 957 (1986), two different events were arguably proximate causes of damage to a house's foundation:
(1) builder negligence in failing to install a proper drainage system (a peril covered under the homeowners insurance policy);
(2) "earth movement" (a peril excluded from coverage). 106 Wn.2d at 809.
The Court held that "where an insured risk itself sets into operation a chain of causation in which the last step may have been an excepted risk, the excepted risk will not defeat recovery." 106 Wn.2d at 815.