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183341P.pdf   04/20/2020  Joseph J. Henderson & Sons  v.  Travelers Property Casualty
   U.S. Court of Appeals Case No:  18-3341
   U.S. District Court for the Southern District of Iowa - Davenport   
[PUBLISHED] [Wollman, Author, with Colloton and Benton, Circuit Judges] Civil case - Insurance. The "faulty workmanship" exclusion in the policy at issue did not contain an anticoncurrent-cause provision and did not bar Henderson's recovery when the underlying loss is caused both by an excluded event, such as faulty workmanship, and an event otherwise covered, such as the windstorm which occurred here; under Iowa law, concurrent causes are independent causes even though each cause does not independently cause the relevant harm; the argument that the extent of the damage caused by the windstorm was dependent on the faulty workmanship rejected; Henderson presented evidence at trial that the windstorm was the catalyst for the damage to the roof and a reasonable juror could have found that faulty workmanship was not the sole proximate cause of the damage; claim the court plainly erred in instructing the jury on proximate cause rejected; claim for remittitur rejected.