Case file · Oklahoma
West v. State Farm: The Oklahoma Hail Claims Lawsuit, Its Unsealed Documents, and What They Show
An Oklahoma family’s disputed roof claim became a window into how one of the country’s largest insurers manages wind and hail losses. On 21 August 2026 the West plaintiffs filed a response with 44 exhibits, newly unsealed: internal emails, the Fire Model Enhancement rollout, planning decks, agent complaints, State Farm’s own roofing guidelines, and the orders that made them public.
The source: Mantis Claims Group
The full case study is by Carl B. Brock, public adjuster, Mantis Claims Group, who hosts every exhibit as a free, unaltered court-record download. This page summarises that work and links each document to its original home; the directory’s reference entry with the abstract and citation list is in the technical-papers series.
The case at a glance
| Homeowners | Neil West and Lacy West |
|---|---|
| Defendants | State Farm Fire and Casualty Company; Nancy Holcomb Ins. Agency, Inc. |
| Case number and court | CJ-2025-135, District Court of Comanche County, Oklahoma (Judge Grant Sheperd) |
| Filed | February 28, 2025; removed to federal court April 4, 2025; remanded August 21, 2025 |
| The loss | A June 15, 2023 weather event, as State Farm describes it in its own August 2026 motion |
| The amount in dispute | About $50,000 to replace a roof, again per State Farm’s motion. A disputed figure, not an award. |
| Claims pleaded | Breach of contract and bad faith against the insurer; negligent procurement against the agency; constructive fraud and negligent misrepresentation (State Farm’s summary of the pleadings) |
| What was unsealed | The plaintiffs’ 21 August 2026 response with 44 exhibits, after the court’s 20 August de-designation order |
| Trial setting | November 2, 2026, as stated in the August 21 filing. Settings change. |
| Verdict | None located in the record reviewed through September 19, 2026 |
A docket-reading trap: the OSCN case page shows an April 7, 2025 “closed” entry. That is the removal to federal court, not a disposition; the case came back and the docket runs on.
What happened, in order
- April 18, 2018. Date of State Farm’s Wind/Hail Roofing Guidelines, OG 75-160 (Exhibit 26).
- June 26, 2020. The Fire Model Enhancement presentation records a wind/hail kickoff in Dallas County, Texas (Exhibit 30).
- December 17, 2020. The same presentation records expansion to all states.
- 2021. Playbooks, management reviews, dashboards, training and agent complaints appear across the correspondence (Exhibits 8–12, 17–19, 22–23).
- January 16, 2023. An internal email describes about $1.4 billion less indemnity from 2020 to 2021 and a falling full-to-partial roof ratio (Exhibit 6).
- June 15, 2023. The weather event behind the West claim, per State Farm’s motion (Exhibit 41).
- February 28, 2025. West filed in Comanche County; removed to the Western District of Oklahoma on April 4 and remanded on August 21, 2025.
- December 31, 2025. Hursh journal entry denies several motions to quash corporate and executive depositions (Exhibit 39).
- January 23, 2026. State Farm seeks limited corporate-discovery consolidation across 22 Oklahoma County cases (Exhibit 35).
- May 21, 2026. Judge Dishman’s communicated ruling denies consolidation of written discovery (Exhibit 37).
- June 23, 2026. The West defense witness list is filed; the Oklahoma Supreme Court issues 2026 OK 51 and the separate No. 123812 order (Exhibit 42).
- June 24, 2026. The Oklahoma Attorney General files a civil enforcement action, CJ-2026-1066, Cleveland County.
- August 20, 2026. Judge Sheperd’s order de-designates the identified materials (Exhibit 32).
- August 21, 2026. The West plaintiffs file the response and counter-motion with the 44-exhibit packet.
- September 24, 2026. Docketed hearings on a motion to compel, the Rule 4 counter-motion and executive-deposition consolidation.
- November 2 and December 7, 2026. Trial settings identified in the filing for West and Hursh respectively.
Historical rows come from the exhibits themselves; court rows from the dockets and orders. A scheduled date is not a report that the event occurred.
What the documents show, and what they don’t
A coordinated wind/hail initiative, not one adjuster’s opinion.
Planning, benchmarks, manager review, training and monitoring connect across Exhibits 3–5, 9–13 and 30. A coordinated programme is not itself unlawful; the question is whether it improved correct outcomes or steered handlers away from covered losses.
The $1.4 billion email is real, and it is not a theft finding.
Exhibit 6 describes lower indemnity 2020→2021 with volume down and severity up, and full-to-partial roof ratios of 5.6:1, 2.0:1 and 2.2:1. A ratio is not a denial rate, and the email does not say how much of the change was correct handling.
The $78.8 million example carries a qualification.
Exhibit 7 frames a one-point difference as claims “without damage and not covered.” Plaintiffs can test that category; a reader cannot delete the qualifier and call it an instruction to deny 5,000 valid claims.
State Farm’s own agents complained.
Exhibits 1, 17, 18, 20 and 21 are agents describing customer harm and reputational cost, with the company’s responses attached. Two of them are the same chain filed twice.
Some decisions were corrected upward.
Exhibit 21 records an internal review concluding the original findings supported replacement; Exhibit 10 tracks closed-without-payment claims that became paid full roofs. The direction of a reversal matters.
The 2018 roofing guidelines are the practical exhibit.
OG 75-160 (Exhibit 26) addresses damage as reduced water-shedding or reduced life expectancy, repairability and test areas, waste of 5/10/15%, steep charges from 7/12, two-story labour, tear-off and prior losses. Historical carrier guidance, not a current entitlement.
If you are the roofing contractor
Exhibit 26 is the carrier’s own historical estimating position on waste, steep and two-story charges, tear-off and repairability. The reference entry sets out how to cite it and where it stops.
The contractor readingIf you are the public adjuster
Ratios are not denial rates, training is not the contract, and the record shows corrections in both directions. The reference entry turns the exhibits into file-level questions.
The adjuster readingEvery document, with a note on what it is
Page numbers are the physical pages of the 285-page filing. Files open on mantisclaims.com, which hosts them unaltered with an extraction manifest and SHA-256 hashes.
The complete filing — 285 pages as scanned by the clerk. PDF, 94.8 MB.The plaintiffs’ brief — response and counter-motion, filing pp. 1–19. PDF, 5.6 MB.
Exhibits 1–31: State Farm’s internal documents
| Exhibit | Filing pages | What it is | Download (Mantis) |
|---|---|---|---|
| Exhibit 1 | pp. 20–29 10 pages | Agent complaint and internal service review Chad Harris; Gwen Hodgson; Nicole Manduca; Kathy Ress A separate Ohio window claim, not the West roof claim. Includes complaints and a corrective-action review. | PDF, 3.6 MB |
| Exhibit 2 | pp. 30–33 4 pages | 2022 Fire and AWC Claims: Quality Pillar Strategy Dana Jokerst; David Chikahisa; Eric Daly; Nicole Manduca Identifies quality-pillar leadership, measures, and tactical planning. | PDF, 1.3 MB |
| Exhibit 3 | p. 34 1 page | Full roof replacements and opportunity discussion Nicole Manduca; Greg Robinson June 2020 discussion of full-roof replacement, small hail, light wind, and tracking payment codes. | PDF, 0.3 MB |
| Exhibit 4 | p. 35 1 page | Indemnity opportunity and industry comparison Nicole Manduca; Dana Jokerst December 2020 discussion linking analytical opportunities to indemnity spending. | PDF, 0.4 MB |
| Exhibit 5 | pp. 36–42 7 pages | 2020 Fire Weather Leadership Business Plan Fire Weather leadership The 57% figure combines wind/hail and non-weather water; wind/hail alone is shown at 40% of net paid indemnity. | PDF, 2.1 MB |
| Exhibit 6 | p. 43 1 page | 2020-2021 indemnity decrease and roof-payment ratios Nicole Manduca; Tommy Higa-Seaver; Terrie Lemon January 2023 retrospective: about $1.4 billion lower indemnity, with volume down and severity up; full-to-partial ratios. | PDF, 0.4 MB |
| Exhibit 7 | pp. 44–45 2 pages | One-percentage-point financial example Tom Moss; Nicole Manduca Conditional example involving claims described as undamaged and uncovered; not a finding of wrongful nonpayment. | PDF, 0.8 MB |
| Exhibit 8 | p. 46 1 page | Wind/hail dashboard discussion Kathy Ress; Nicole Manduca March 2021 dashboard and leadership discussion. | PDF, 0.3 MB |
| Exhibit 9 | p. 47 1 page | Management review and customer conversations Wendy Mazza; Nicole Manduca September 2020 discussion of expanding review and communicating claim decisions. | PDF, 0.5 MB |
| Exhibit 10 | pp. 48–52 5 pages | Roof-payment trends, benchmarks, and reversals Nicole Manduca; Kathy Ress; Scott Welsh; Tom Moss; Zach Olson Contains full/partial roof charts and a closed-without-payment-to-paid-full-roof metric. Reversal direction matters. | PDF, 1.9 MB |
| Exhibit 11 | p. 53 1 page | Wind/hail playbook distribution Nicole Manduca and distribution group June 2021 communication, monitoring, and execution instructions. | PDF, 0.4 MB |
| Exhibit 12 | pp. 54–56 3 pages | Playbook communication and huddle planning Nicole Manduca; Kathy Ress; Scott Welsh; Steve Meulemans; Angela Mitchell Drafting, customer communications, and leadership follow-through. | PDF, 1.0 MB |
| Exhibit 13 | pp. 57–58 2 pages | Manager approvals and revisiting earlier plays John Christensen; Tom Moss; Scott Welsh September 2023 discussion of management approval results; not an overall claim-approval rate. | PDF, 0.5 MB |
| Exhibit 14 | pp. 59–65 7 pages | Fix Profit Task Force correspondence Jordan Coad; John Christensen; Jon Farney; Michael Roper and others Claims and profitability discussions. The 39% closed-without-payment passage appears in an auto-related financial discussion, not a roof-claim dataset. | PDF, 2.2 MB |
| Exhibit 15 | pp. 66–67 2 pages | Changing targets to selections in presentation materials Kimberly Rose; Scott Welsh and colleagues October 2023 editing instructions. Wording changes invite questions but do not independently establish unlawful conduct. | PDF, 0.7 MB |
| Exhibit 16 | pp. 68–71 4 pages | Quality Pillar opportunity-sizing framework Jordan Coad; Nicole Manduca; John Christensen; Tyrone Smith August 2023 planning and connections to the profit-task-force process. | PDF, 1.6 MB |
| Exhibit 17 | pp. 72–76 5 pages | Agent Tracy Blair Haus complaint and follow-up Tracy Blair Haus; Kathy Ress; Renee Bass-Taylor and others Kentucky agent concerns about repair estimates, customer outcomes, and reputation; includes an internal response plan. | PDF, 2.0 MB |
| Exhibit 18 | pp. 77–79 3 pages | Agency leadership complaints about fire and roof claims Jennifer Chandler; Debbie Myers; Nicole Manduca April 2021 concerns over communications, claim handling, and the roof-claim philosophy. | PDF, 1.0 MB |
| Exhibit 19 | pp. 80–86 7 pages | 2021 agency leadership training outline Tom Moss and agency/claims leaders Virtual inspections, REIAP, Hancock and Seek Now, policy endorsements, and customer communications. | PDF, 1.7 MB |
| Exhibit 20 | pp. 87–96 10 pages | Agent complaint chain, repeated with different emphasis Chad Harris; Gwen Hodgson; Nicole Manduca; Kathy Ress Substantially repeats Exhibit 1. Do not count it as a second independent customer event. | PDF, 3.7 MB |
| Exhibit 21 | pp. 97–100 4 pages | Agent Robert Garner complaint and claim correction Robert Garner; Tyler Deneault; Kathy Ress; Nicole Manduca Separate Ohio roof claim; internal review concluded the original findings supported replacement. Not the West claim. | PDF, 1.5 MB |
| Exhibit 22 | pp. 101–123 23 pages | Growing Together: 2021 market-area partnership Wensley Herbert; Kathy Ress; Ami Kuhlman; Beatrice Lee; Juan Parilo Agent distrust, claim communications, training, and joint agency/claims strategy. | PDF, 5.8 MB |
| Exhibit 23 | pp. 124–125 2 pages | April 2021 quarterly business review OVP Herbert; Fire Weather and AWC Quality, customer experience, management involvement, and operating expense. | PDF, 1.2 MB |
| Exhibit 24 | pp. 126–130 5 pages | April 2020 Oklahoma agency conference call Ami Kuhlman; Vince Watson; broad distribution Storm-response call announcement. A name in a bulk distribution list does not establish personal responsibility for a disputed claim. | PDF, 2.7 MB |
| Exhibit 25 | pp. 131–134 4 pages | Haag hail/wind training development Tom Moss; Melissa Grimmett; Brad Rushton; Tanya Potts March 2020 drafts distinguish engineering instruction from coverage under an insurance policy. | PDF, 1.7 MB |
| Exhibit 26 | pp. 135–153 19 pages | OG 75-160: Wind/Hail Roofing Guidelines, April 18, 2018 State Farm operating guide Inspection, repairability, functional damage, waste, steep/height charges, starter, ridge, prior losses, experts, and related topics. Historical guidance, not proof of current terms. | PDF, 9.6 MB |
| Exhibit 27 | pp. 154–160 7 pages | 2021 quality plan and Haag training requirements Eileen Colbert; Pete McArdle; Katina Butler; Gwen Hodgson and others Yearly refresher requirement and new-handler training logistics. | PDF, 2.1 MB |
| Exhibit 28 | pp. 161–163 3 pages | MyBlock training completion tracking Tanya Potts; Marie Dyer; Heather Hanselka; Tom Moss and others Internal reports and completion tracking. | PDF, 1.0 MB |
| Exhibit 29 | pp. 164–166 3 pages | 2022 wind/hail training and repair-versus-replace guidance Walter Phillips; Tom Moss; Scott Welsh and training staff Includes a scenario supporting slope replacement even below a 50% repair-cost comparison. | PDF, 1.1 MB |
| Exhibit 30 | pp. 167–177 11 pages | Fire Model Enhancement presentation Fire/claims leadership Rollout dates, selected small-hail/light-wind populations, manager reviews, benchmarks, and financial charts. | PDF, 2.2 MB |
| Exhibit 31 | p. 178 1 page | HRU Stewardship Redesign project record Tyrone Smith listed as VPO sponsor 2023 workflow, ownership, and expense/quality project record; not a statement that every roof replacement must be overturned. | PDF, 0.2 MB |
Exhibits 32–44: orders, motions, transcripts and correspondence
| Exhibit | Filing pages | What it is | Download (Mantis) |
|---|---|---|---|
| Exhibit 32 | pp. 179–188 10 pages | August 20, 2026 confidentiality de-designation order Judge Grant Sheperd Grants relief in part but leaves the broader protective order in place. | PDF, 2.7 MB |
| Exhibit 33 | pp. 189–191 3 pages | January 9, 2026 hearing transcript excerpts Judge Don R. Dishman; related Adair/Cox/Pruitt proceedings Selected transcript pages, not a complete hearing transcript. | PDF, 0.7 MB |
| Exhibit 34 | pp. 192–214 23 pages | January 16, 2024 State Farm opposition to consolidation Nida litigation; State Farm and Sheryl Mandeville Historical opposition to broader reassignment/consolidation, attached by the West plaintiffs. | PDF, 7.1 MB |
| Exhibit 35 | pp. 215–229 15 pages | January 23, 2026 motion for limited corporate-discovery consolidation Adair; 22 identified Oklahoma County cases State Farm explains its efficiency rationale and identifies the proposed consolidation candidates. | PDF, 4.5 MB |
| Exhibit 36 | pp. 230–238 9 pages | February 10, 2026 objection to partial consolidation Adair plaintiff and counsel Opposition addressing case-specific agents, facts, discovery posture, and governing rules. | PDF, 2.7 MB |
| Exhibit 37 | pp. 239–247 9 pages | May 21, 2026 court communication on consolidation Judge Dishman through courtroom staff; counsel Written discovery consolidation denied; potential deposition limits left for discussion. | PDF, 3.5 MB |
| Exhibit 38 | pp. 248–260 13 pages | July-August 2026 scheduling and consolidation emails Counsel and Judge Dishman courtroom staff Communications about a status conference and coordination. | PDF, 5.2 MB |
| Exhibit 39 | pp. 261–264 4 pages | December 31, 2025 Hursh journal entry Judge Amy Palumbo Denies several motions to quash corporate and individual depositions. | PDF, 1.0 MB |
| Exhibit 40 | p. 265 1 page | July 2026 West deposition order Judge Grant Sheperd Handwritten hearing order, filed July 24, concerning Ress, Herbert, Moss, and Welsh. | PDF, 0.3 MB |
| Exhibit 41 | pp. 266–279 14 pages | August 2026 State Farm motion to consolidate executive depositions West; State Farm; four executives Includes the insurer's own summary of the June 15, 2023 loss, approximately $50,000 roof dispute, and pleaded causes of action. | PDF, 4.1 MB |
| Exhibit 42 | p. 280 1 page | June 23, 2026 Oklahoma Supreme Court order, No. 123812 State Farm v. Palumbo; Hursh and other real parties Application to assume original jurisdiction denied. Different proceeding from No. 123739 / 2026 OK 51. | PDF, 0.2 MB |
| Exhibit 43 | pp. 281–284 4 pages | August 4, 2026 Hursh hearing transcript excerpts Judge Amy Palumbo Selected pages addressing depositions, document production, and trial preparation. | PDF, 1.0 MB |
| Exhibit 44 | p. 285 1 page | August 4, 2026 Hursh court minute Judge Amy Palumbo Deposition and production directions; contains permission to use production in West. | PDF, 0.5 MB |
44 exhibits. An old “Confidential” stamp on a page is not evidence that it remains sealed; the 20 August 2026 order de-designated these materials. This is one filing, not State Farm’s full discovery production.
Questions people ask
- Is West v. State Farm a class action?
- No. It is an individual action by named homeowners. Coordinated depositions and limited procedural consolidation elsewhere do not make it one, and no class-certification order was located.
- Did a court find that State Farm withheld $1.4 billion?
- No such finding was located. The figure is an internal email’s description of lower indemnity payments from 2020 to 2021. Whether any part of it reflects wrongful nonpayment is a separate evidentiary question.
- Were all of State Farm’s internal records made public?
- No. The 20 August 2026 order de-designated identified materials and left the wider protective order in place. This packet is one filing and its 44 exhibits.
- Do the guidelines prove my roof must be replaced?
- Not by themselves. They give historical context and better questions. Coverage still turns on the policy, the physical damage, causation, repair feasibility and the governing law where the property sits.
- Is the $50,000 a settlement or verdict?
- No. It is the approximate replacement amount in State Farm’s own description of the dispute.