Making the Policyholder Whole: Property Insureance Coverage for Both the Damaged and Undamaged Parts of a "Pair of Set"

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Assoc. v. Harleysville Worcester Ins. Co. , 995 F.Supp.2d 1035 (D.Minn. 2014) (the court allowed to go to the jury the issue of coverage for matching shingles on a roof, where certain shingles were damaged and others were not).

Indeed, an all-risk policy can contain an anti- pair and set clause, whereby the policy expressly disavows paying for any value beyond the specific damaged item. See Karcher v. Philadelphia Fire & Marine Ins. Co., 108 A.2d 638 (N.J. Super. 1954) (no coverage beyond a lost diamond set within a more elaborate ring where a jewelry policy limited recovery to the value of a single part of a set). The existence of such anti-pair and set clauses confirms that in the absence of such a clause, all-risk RCV coverage inherently includes pair and set coverage without the need for an express grant of coverage through a pair and set clause.

Be Aware

For good measure, a policyholder should be sure that their policy includes the pair and set clause, as other courts have applied a stricter approach in its absence. See Jaskierny v. Mutual of Omaha Ins. Co., No. Civ. A. 96-1841, 1996WL 736975 (E.D. La. Dec. 19, 1996) (in the absence of the clause, there was no coverage for undamaged custom-made...

For good measure, a policyholder should be sure that their policy includes the pair and set clause …


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