Insurance coverage disputes often turn on a single word as to how parties frame the cause of the loss. In Wake Chapel Church, Inc. v. Church Mutual Insurance Company, the Fourth Circuit Court of Appeals has now made unmistakably clear how causation works in an all-risk property insurance policy governed by North Carolina law. 1 I previously blogged about the trial of this case in Church Forced to Trial to Obtain Insurance Benefits for Roof Loss.
The facts are familiar to anyone who handles roof cases. After a December 2018 snowstorm, Wake Chapel Church discovered significant scratching and coating failure on its standing seam metal roof. The insurer denied coverage, arguing the damage stemmed from inherent defects or improper coating rather than from snow and ice. A jury disagreed and awarded $1.1 million. The insurer appealed, arguing that North Carolina requires a covered cause to be the “efficient and predominant cause” of the loss in first-party property cases.
The Fourth Circuit rejected that argument. The court framed the issue directly and used language that every North Carolina coverage practitioner should memorize. It held:
Avis and later cases compel the conclusion that ‘all-risk’ insurance policies provide coverage where a cause that is not subject to an exclusion at least partially contributed to the damage. Because the parties do not dispute that CMIC issued Wake Chapel an ‘all-risk’ policy, the district court correctly employed a causation standard in line with Avis. 2
That is not a subtle holding. It is a clear endorsement of North Carolina’s causation test in the all-risk context.
For years, insurers have attempted to resurrect Wood v. Michigan Millers and its “efficient and predominant cause” language to narrow first-party coverage. That argument did not prevail here. The Fourth Circuit made an important distinction: Wood involved a named-peril policy. Wake Chapel involved an all-risk policy. That difference matters.
Under North Carolina’s interpretation of all-risk policies, once the insured proves a fortuitous direct physical loss, coverage exists unless an exclusion applies. And when multiple causes contribute to the damage, coverage remains so long as the excluded cause is not the sole cause. In other words, the presence of a defect does not automatically defeat coverage if a covered peril, such as snow and ice, at least partially contributed to the loss.
This case also reinforces another practical lesson. Coverage litigation is often won or lost at the expert level. The insurer argued the roof coating was defective and would have failed regardless of snow. The insured’s engineer testified that sliding ice and snow contributed to the scratching and delamination. The jury was entitled to believe him. The appellate court would not second-guess that determination.
The insurer also challenged fortuity and the requirement that the loss “commence” during the policy period. Those arguments failed as well. The court emphasized that fortuitous means not certain to occur, and a heavy snowstorm in North Carolina qualified. As for timing, circumstantial evidence and expert opinion were sufficient for the jury to conclude the damage began during the policy period.
For practitioners, the lesson is straightforward. In North Carolina all-risk cases, the causation inquiry is not about which cause predominates. It is about whether a covered cause at least partially contributed. If it did, and no anti-concurrent causation clause controls, coverage is likely to survive.
Wake Chapel is not just about snow on a church roof. It is about how North Carolina courts interpret all-risk property insurance contracts. It reminds us that causation in the all-risk context is often a state-by-state analysis. This case also reminds us that insurance promises are not erased simply because multiple forces were at work in producing a loss. To me, it was clear that the heavy snow started all of this damage.
Insurance is supposed to provide protection when unexpected events cause damage. In North Carolina, when a covered cause at least partially contributes to that damage, the promise must be honored.
I suggest that you also read a blog by Beaujeaux de Lapouyade, North Carolina – Concurrent Causation.
Thought for the Day
“To be rather than to seem.”
— North Carolina State Motto
1 Wake Chapel Church v. Church Mutual Ins. Co., No. 25-1485 (4th Cir. Feb. 19, 2026).
2 Id. at *6.