Were insureds injured by agent’s negligence?
In 2002, Jerry and Becky French purchased a manufactured home for $76,950. They worked with their long-time insurance agent, Jane Hodson, to purchase State Farm homeowners insurance for their new home. As part of the purchase process, Hodson asked Jerry various questions and entered data into an “insurance to value” (IV) calculator to arrive at a replacement cost of $173,200. The IV calculator is an electronic tool insurance agents use to determine a “reasonably accurate estimate of current replacement cost” coverage. Hodson also determined that the Frenches would need additional coverage during “construction” of the home (even though the home was a manufactured home), so she added a “dwelling under construction” endorsement to the policy. The Frenches also purchased an “increased dwelling limit” endorsement that increased their coverage by $34,640, as well as an additional $130,000 of personal property coverage. State Farm offered different insurance policies “determined by the type o