Storm damage to roofs and siding is one of the most common homeowners’ insurance claims. When a only portion of a roof or a field of siding is damaged, repair or replacement will typically result in a mismatch in appearance. Even if the exact same material can be obtained, new shingles or siding will generally not match the appearance of existing materials that have been in place on the home for a number of years and thus have a weathered appearance. In these circumstances, insureds often claim that they are entitled to recover the cost of replacing all of the shingles or siding, not just the damaged material. These are colloquially referred to a “matching claims.”

The insureds’ position is based on the premise that property insurance policies are intended to restore the insured to its pre-loss position, as in Fazio v. State Farm Fire & Casualty, No. 16-1987, 2017 U.S. Dist. LEXIS 41604, at *20 (E.D. Pa. 2017). Prior to the loss the insured had a home with an undamaged roof with a uniform appearance. Accordingly, insureds reason, the policy must pay the cost of providing the insured with an undamaged roof of uniform appearance.