People's Insurance Counsel Division v. State Farm Fire & Casualty Insurance, 76 A.3d 517

During a winter blizzard in 2010, the Taylors’ detached carport collapsed under ice/snow in Maryland.
State Farm denied the claim, arguing the carport was not a “building” and thus not covered for collapse.
The Taylors and PICD filed a complaint with the Maryland Insurance Administration alleging unfair claim practices.
MIA investigation concluded no violation; the ADC’s findings were adopted by the Insurance Commissioner.
PICD sought judicial review; the circuit court affirmed the MIA decision.
The issue on appeal was whether the MIA decision denying coverage was legally correct and supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether MIA’s denial was legally correct and supported by substantial evidence	PICD contends the policy language defines ‘building’ too narrowly and the denial was ad hoc	State Farm argues policy language is plain and unambiguous; denial followed the contract	Yes; the MIA decision was supported by substantial evidence and based on proper contract interpretation.

Berkshire Life Ins. Co. v. MIA, 142 Md.App. 628 (2002) (arbitrary or capricious standard for unfair claim practices)
N. River Ins. Co. v. Mayor & City Council of Balto., 343 Md. 34 (1996) (interpretation of insurance contracts; standard for coverage)
Empire Fire and Marine Ins. Co. v. Liberty Mut. Ins. Co., 117 Md.App. 72 (1997) (contract construction principle; whole-document view)
MAMSI Life & Health Ins. Co. v. Callaway, 375 Md. 261 (2003) (ambiguous term determination; whether term is ambiguous as a matter of law)
Philadelphia Indem. Ins. Co. v. Md. Yacht Club, Inc., 129 Md.App. 455 (1999) (ambiguity and interpretation of policy terms)