Heartland Co-Op v. Nationwide Agribusiness Insurance Company, 23-0156

Heartland Co-op, an agricultural business with multiple locations, held a commercial insurance policy from Nationwide covering earnings and extra expenses.
In August 2020, a derecho (powerful windstorm) damaged 48 of Heartland's locations.
Nationwide paid Heartland about $131 million for property losses, including $3 million for business income and extra expense coverage, but denied further claims above the $3 million limit.
Heartland argued each damaged location constituted a separate covered loss, entitling it to $3 million per location.
Nationwide argued the policy imposed a single $3 million cap for earnings and extra expense losses across all locations from the storm.
The district court granted summary judgment to Nationwide; the Iowa Court of Appeals affirmed; the Iowa Supreme Court granted further review and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Interpretation of "any one loss" in the insurance policy	Each location's business interruption is a separate loss, enabling $3 million in coverage per location	The entire derecho constitutes a single loss, with a $3 million cap across all locations	The policy unambiguously applies the $3 million limit to aggregate losses across all locations for the single event
Whether the policy is ambiguous	Policy language can reasonably be read to provide per-location coverage	Policy language only supports entity-level, not per-location, coverage	Not ambiguous; coverage is for total loss to the entity, not per location
Consideration of internal accounting in policy construction	Heartland’s accounting recognizes losses by location, supporting per-location interpretation	Internal accounting cannot alter policy language or meaning	Insured’s internal records are irrelevant to policy interpretation
Precedential impact of Steel Products Co. v. Millers Nat’l Ins.	Steel Products supports per-location interpretation	Steel Products involved only one location and supports entity-level loss principles	Steel Products is distinguishable and supports the court’s interpretation

Boelman v. Grinnell Mut. Reins., 826 N.W.2d 494 (Iowa 2013) (sets out rules for interpreting ambiguous insurance policies; premiums and commercial reasonableness inform interpretation)
Just v. Farmers Auto. Ins., 877 N.W.2d 467 (Iowa 2016) (insurance policy ambiguity and interpretation standards)
Steel Products Co. v. Millers Nat’l Ins., 209 N.W.2d 32 (Iowa 1973) (business interruption policy covers loss to business entity as a whole)
Amish Connection, Inc. v. State Farm Fire & Cas. Co., 861 N.W.2d 230 (Iowa 2015) (disagreement does not create ambiguity in an insurance policy)