Slife v. Farmers Mut. Hail Ins. Co., No. 3-1099 / 13-0111, 2014 Iowa App. LEXIS 109 (Iowa Ct. App. Feb. 5, 2014)

(the insureds purchased yearly policies from the insurer to cover their dairy operation; their 2009-2010 policy included a provision requiring the insureds to bring any action against the insurer within one year; the 2010-2011 policy (effective in November of 2010) gave the insureds two years to pursue litigation against the insurer; in January of 2010, the roof of the insureds’ barn collapsed, and the insurer denied coverage; nearly two years after the collapse, the insureds filed an action against the insurer for breach of contract and negligence; the district court granted summary judgment to the insurer on the grounds that the one-year contractual limitation in the 2009-2010 policy barred the action; on appeal, the court affirmed, ruling that the language of the policy was clear and susceptible to only one reasonable interpretation; the court also ruled that the provision was not unconscionable; the insureds had a reasonable period of time to file their action).