Rizzo v. State Farm Insurance, 305 P.3d 519

Water damage to Rizzo’s basement under State Farm homeowners policy; policy excludes surface water and water below ground; two losses in May and December 2010; district court granted summary judgment ruling no coverage; Rizzo sought amendments and discovery relief; appellate record on appeal challenged; Court affirms district court’s decisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the district court's summary judgment proper on all claims?	Rizzo argues material facts disputed; expert causation creates genuine issues.	State Farm contends undisputed policy exclusions foreclose coverage.	Yes; summary judgment proper; no coverage under policy.
Was the record-deletion denial properly exercised?	Rizzo sought deletion of excess clerks’ records.	Clerk’s record was deemed sufficient and appropriate.	Yes; district court did not abuse discretion.
Did the district court properly dismiss breach of contract claim?	Policy ambiguity should be construed in plaintiff’s favor; broader coverage alleged.	Policy unambiguous; exclusions apply; no coverage.	Yes; contract claim properly dismissed.
Was the bad faith claim properly dismissed?	Bad faith exists if contract breached and denial was improper.	No independent bad faith after contract dismissal.	Yes; bad faith claim properly dismissed.
Was the motion to amend and related claims properly denied?	Want to add punitive damages, personal injury, diminution in value.	Courts have discretion; lack of evidence; health warnings not duties.	Yes; district court did not abuse its discretion.

Lamar Corp. v. City of Twin Falls, 133 Idaho 36 (1999) (abuse-of-discretion standard for record/ transcript matters)
Farm Bureau Mut. Ins. Co. of Idaho v. Eisenman, 153 Idaho 549 (2012) (summary judgment standard; interpretation of policy terms)
Dayley v. City of Burley, 96 Idaho 101 (1974) (distinguishing rain from surface water in other contexts)
Union Cent. Life Ins. Co. v. Albrethsen, 50 Idaho 196 (1930) (distinguishing surface water concepts; general water law context)
Mortensen v. Stewart Title Guar. Co., 149 Idaho 437 (2010) (implied covenant of good faith and fair dealing in insurance)