The U.S. Court of Appeals for the Eighth Circuit ruled that Liberty Mutual Insurance Company properly denied coverage for one of two storm-damaged barns on a Missouri farm, affirming a lower court's summary judgment in favor of the insurers in *Matthew Achey v. Liberty Mutual Insurance Co.* (8th Cir. 2026).
The case arose from a December 2021 storm that damaged two of three hoop barns on Matthew and Jessica Achey's farm in Vernon County, Missouri. While the insurers paid for damage to the couple's 44' x 160' barn, they denied coverage for the other damaged structure measuring 44' x 208'. The Acheys subsequently sued Liberty Mutual Insurance Company and Ohio Security Insurance Company for breach of contract and vexatious refusal to pay.
The dispute centered on the specific language in the Acheys' insurance policy and the circumstances surrounding the addition of barn coverage. In February 2021, the Acheys' insurance broker, Specialty Risk Insurance, had requested a quote from the insurers to add three barns to the policy, with dimensions of 44' x 160', 44' x 208', and 44' x 320'. However, no quote was provided at that time.
When the Acheys' policy was renewed in July 2021, the insurers issued a new annual policy that covered their residence, designated as "Location 0001," and their farm, designated as "Location 0002," but notably included no coverage for outbuildings. The coverage gap was addressed the following month when Specialty Risk again contacted the insurers in August 2021, this time requesting that a barn measuring 44' x 160' be added to location number two, retroactive to July 27, 2021.
The August request specified that the barn would be "Used for Hay/Machinery" and sought $150,000 in coverage. In response, the insurers issued an endorsement to the policy effective on the requested date with the specific language "ADDED HAY/MACHINERY BARN AT LOC #2 - $150,000," along with a new policy declaration.
The precise wording of this endorsement became central to the legal dispute. The Acheys argued that the policy language was ambiguous and should cover both damaged barns. However, the insurers maintained that the policy clearly specified coverage only for the 44' x 160' barn, as that was the only structure specifically added to the policy through the August endorsement.
The U.S. District Court for the Western District of Missouri in Springfield initially granted summary judgment in favor of the insurance companies, finding that the policy was unambiguous and covered only the 44' x 160' barn. The district court's analysis focused on the specific language used in the policy endorsement and the clear dimensions referenced in the coverage addition.
On appeal, the Acheys challenged this interpretation, but the Eighth Circuit Court of Appeals affirmed the lower court's decision. Circuit Judge Kobes wrote the opinion for the three-judge panel, which also included Circuit Judges Benton and Grasz. The appeals court agreed that the policy language was clear and unambiguous, supporting the insurers' position that coverage extended only to the specifically identified barn.
The decision illustrates the challenges that agricultural property owners face when seeking insurance coverage for farm structures. The case demonstrates how precise policy language and clear communication between insurers, brokers, and policyholders can significantly impact coverage determinations. The timing and specificity of coverage requests proved crucial, as the February 2021 request for quotes on multiple barns did not result in actual coverage, while the August 2021 request for the specific 44' x 160' barn did.
For farmers and agricultural property owners, the ruling serves as a reminder of the importance of carefully reviewing insurance policies and endorsements to ensure that all intended structures are explicitly covered. The case also highlights the potential risks of assuming that similar structures on the same property will automatically receive the same coverage treatment.
The decision reflects broader legal principles regarding insurance contract interpretation, particularly the courts' tendency to enforce clear policy language as written when determining coverage disputes. Insurance companies generally benefit when policy terms are specific and unambiguous, as demonstrated by the successful defense in this case.
The Acheys' case was submitted to the appeals court in September 2025 and decided in February 2026, reflecting the typical timeline for federal appellate proceedings. The case number 24-1979 indicates it was among the appeals filed in 2024.
This ruling may influence future insurance coverage disputes involving agricultural properties and could encourage both insurers and policyholders to be more precise in their coverage documentation. The decision reinforces the principle that insurance coverage is generally limited to what is specifically stated in the policy documents, absent ambiguous language that would favor the policyholder's interpretation.