California Court of Appeal, (Ret.)
First District, Division Two
Mediator • Arbitrator • Discovery Referee • Appellate Consultant
Appointed Umpire in multiple Appraisal Arbitrations under provisions of California Insurance Code Section 2071, including water damage and claims arising from the wildfires in the wine country and Central Valley.
Justice Lambden was the author of Devonwood Condominium Owners Assoc. v. Farmers Insurance Exchange (2008) 162 Cal. App. 4th 1408.
Devonwood was applied in an award based on the insurer’s argument that although the damage was undisputed the cause of the water damage could have been from a source not covered by the policy.
Lee v. California Capital Ins. (237 Cal. App. 4th 1154) was applied conjunction with Devonwood in cases where the disputed scope of damage by fire/water included items argued not to have been damaged.
Devonwood was applied in awards where parties disputed the coverage of alternative living expenses.