The U.S. Court of Appeals for the Fifth Circuit affirmed a district court's summary judgment in favor of State Farm Fire and Casualty Company in *Cooper v. State Farm* (5th Cir. 2026), a homeowners insurance coverage dispute involving sewage damage exclusions. The three-judge panel, consisting of Circuit Judges Jones, Southwick, and Oldham, unanimously upheld the lower court's ruling that the homeowners failed to establish a genuine dispute of material fact regarding the source of sewage that damaged their Mississippi home.
Circuit Judge Leslie H. Southwick wrote the opinion for the court, noting that Mississippi law governed the coverage dispute and required affirmance of the district court's decision. The case centered on the interpretation of policy language excluding coverage for damage caused by off-premises sewage.
The dispute arose from events in 2022 when Ronald and Shirley Cooper returned to their newly built Madison, Mississippi home from choir practice to discover sewage flowing up through their shower and tub drains into multiple rooms. The Coopers had purchased their home in 2019 and installed what the court described as a "pressurized or forced sewer main system" to handle wastewater from the residence.
The sewage system in question utilized a series of PVC pipes throughout the home to collect wastewater in a grinder pump station. According to court documents, the waste is ground up and pumped away from the home to a utility line, representing a modern approach to residential sewage management in newer construction.
At the time of the sewage backup incident, the Coopers maintained a homeowners insurance policy with State Farm Fire and Casualty Company. When they filed a claim for the resulting property damage, State Farm denied coverage based on policy exclusions related to sewage damage, specifically provisions excluding coverage for off-premises sewage incidents.
The case proceeded to the U.S. District Court for the Southern District of Mississippi, where State Farm moved for summary judgment. The district court granted the motion, finding that the Coopers had not presented sufficient evidence to create a genuine dispute of material fact about whether the sewage originated from sources covered under their policy.
On appeal to the Fifth Circuit, the Coopers challenged the district court's summary judgment ruling, arguing that factual questions remained about the source and classification of the sewage that damaged their property. However, the appeals court found their arguments insufficient to overcome the policy's clear exclusionary language.
The Fifth Circuit's analysis focused on the specific terms of the State Farm policy and how Mississippi insurance law interprets such exclusions. Under Mississippi law, insurance policy exclusions must be clearly stated and unambiguous to be enforceable. The court found that the off-premises sewage exclusion met these requirements and applied to the circumstances of the Coopers' claim.
Circuit Judge Southwick's opinion emphasized that the burden remained on the policyholders to demonstrate that their damages fell within covered perils under the policy. The court found that the Coopers had not met this burden, particularly regarding the critical question of whether the sewage originated from sources that would trigger coverage under the policy terms.
The decision represents a victory for State Farm and reinforces the enforceability of clearly written policy exclusions in homeowners insurance contracts. Insurance companies frequently rely on sewage-related exclusions to limit their exposure to claims involving water damage from sewer backups and similar incidents.
For homeowners, the ruling underscores the importance of carefully reviewing policy language and understanding what types of water damage are covered versus excluded. Many standard homeowners policies contain exclusions for various types of water damage, including sewage backups, flooding, and groundwater intrusion.
The case also highlights the technical complexities that can arise in coverage disputes involving modern residential sewage systems. As more homes utilize advanced waste management systems like the pressurized setup installed by the Coopers, questions about coverage boundaries and exclusion applications may become increasingly common.
The Fifth Circuit's decision in *Cooper v. State Farm* follows established precedent regarding summary judgment standards in insurance coverage disputes. Federal courts applying state insurance law regularly face questions about when factual disputes are sufficient to preclude summary judgment, and this case demonstrates the high bar plaintiffs face in creating genuine disputes of material fact.
The ruling is final unless the Coopers seek further review from the Supreme Court, though the Court rarely grants certiorari in insurance coverage disputes involving state law questions. The decision will likely influence how similar sewage exclusion clauses are interpreted in future cases within the Fifth Circuit's jurisdiction, which includes Mississippi, Louisiana, and Texas.
For the insurance industry, the decision provides additional support for the use of specific exclusionary language in homeowners policies. State Farm's successful defense of its policy exclusions demonstrates the continued viability of carefully drafted coverage limitations in protecting insurers from certain categories of claims.