The roof was impact-resistant shingles. The carrier’s own inspector found hail dings on the valley metal, and the valley metal went into the original scope. Then it came back out. The reason was a cosmetic damage exclusion written for metal roofs, on a house that did not have a metal roof.
That is the short version of Combs v. CSAA General Insurance Company, decided in the Western District of Oklahoma on September 15, 2026, and written up by Chip Merlin on the Property Insurance Coverage Law Blog under the fitting title “Cosmetic Damage Exclusions Are Becoming Anything but Cosmetic.” The homeowner argued that a metal-roof exclusion had no business reaching a shingle roof, and that the damage was functional anyway. The court granted summary judgment to the carrier on both points.
We covered the basics of cosmetic exclusions (what they look like on the dec page and why they are spreading) in six policy endorsements that quietly kill a roof supplement. This post goes one level down: the definitions that decide which parts of a shingle roof an exclusion can reach, and the documentation that separates a dent from a failure on each metal component.
What actually happened in Combs
Per the blog’s account, the CSAA policy excluded “cosmetic loss or damage to metal roof coverings caused by the peril of hail.” Two definitions did the heavy lifting.
Cosmetic loss or damage meant damage that “only alters the physical appearance of the metal roof covering but does not result in damage that allows the penetration of water through the roof covering or does not result in the failure of the roof covering to perform its intended function, to keep out elements over an extended period of time.”
Metal roof covering meant “the metal roofing material exposed to the weather, the underlayments applied for moisture protection, and all flashings required in the replacement of a metal roof covering.”
The homeowner’s reading was reasonable on its face: this language describes a metal roof, and his was shingles. The court held the exclusion applied to roof coverings that are metal, not only to buildings with what most people call a “metal roof.” Valley metal is metal and covers part of the roof, so it was in.
The second argument lost for a simpler reason. The homeowner said the valley damage was functional, but according to Merlin, the court found he had “not presented any evidence to support this assertion.” The claim file had no analysis of whether the dented valley still did its job of channeling water.
Two cautions. This is one federal district court applying one policy’s wording, not a rule for every carrier or state. And the homeowner didn’t lose because valley metal can’t have functional damage. He lost because nobody proved it, which is the part roofers control.
The other side of the coin: “to the same extent”
A few weeks earlier, the Eighth Circuit went the other way on different language. In Cannon Falls Area Schools v. Hanover American Insurance Co., a school district’s metal roofs were dented by hail with no punctures or leaks. Hanover’s exclusion applied only where the damage did not stop the roof from functioning as a barrier to the elements “to the same extent” as before. The court vacated summary judgment for the carrier and sent the case back, reasoning that a roof that once held three feet of snow and now holds two no longer keeps out the elements to the same extent, leak or no leak.
That was a commercial policy, and the case isn’t over. But side by side, the two decisions say the same thing: the definition’s exact wording controls, and so does the evidence. As the Frontera Claims field guide notes, the ISO commercial form (CP 10 36) uses the “to the same extent” test, while other endorsements test for water penetration or “intended function.” Same idea, different bar.
Read the definitions, not the headline
The endorsement title tells you almost nothing; Combs shows how far the definitions underneath can stretch. When the exclusion is on the policy, answer these on the job record before you write a line item:
- What does the exclusion attach to? “Metal roof coverings,” “roof surfacing,” “exterior surfaces,” or a list (siding, gutters, windows, doors). An Insurance.com explainer updated in June 2026 notes these exclusions can cover roofs, siding, windows, doors and exterior walls, individually or together, depending on the form.
- How is that term defined? Does “metal roof covering” include flashings? Underlayment? Does it say “all flashings” or only flashings “required in the replacement of a metal roof covering”? The Combs homeowner leaned on that phrase; the court did not.
- What is the functional test? Water penetration, “intended function,” “over an extended period of time,” or “to the same extent as before.” Each one tells you what your photos need to prove.
- Which perils? Most are hail only, some wind and hail. A limb strike or a wind-lifted flashing is a different conversation.
If the exclusion plainly reaches a component and the damage really is only appearance, that line probably isn’t a supplement line. Knowing that up front saves a rebuttal cycle.
Every metal component on a shingle roof, and what “functional” looks like
Under a Combs-style reading, any metal that forms part of the roof covering is a candidate for a cosmetic argument. So the file for each component has to answer one question: does it still do its job?
| Component | Its job | Functional damage to document | Weak evidence on its own |
|---|---|---|---|
| Valley metal (open or woven-under) | Channel concentrated water off two slopes | Dents deep enough to hold or pond water; dents that push water sideways under shingle edges; splits, creases or fractured coating; fastener or cleat displacement | Shallow, uniform dings with water still running straight down the channel |
| Step and counter flashing | Shed water at walls and sidewalls | Bent legs that lift away from the wall or siding; creases that open a path behind the flashing; torn or displaced counter flashing | Surface marks on the exposed face |
| Drip edge | Carry water past the fascia and into the gutter | Bent or deformed flange that sends water behind the gutter or onto the fascia; kinks that separate it from the deck edge | Dings on the face with the flange still true |
| Pipe jacks | Seal the penetration | Torn, split or punctured boot (often a rubber boot on a metal base); cracked or deformed collar; a base flange bent up out of plane | A dimpled base with an intact, tight boot |
| Box and turtle vents | Exhaust air, keep water out | Punctured or cracked cap; deformation that opens the louver or lets wind-driven rain in; broken welds or seams | Dents that don’t change the opening |
| Ridge vent (metal) | Exhaust air along the ridge | Crushed baffles, collapsed sections that restrict airflow, split seams, lifted end caps | Cosmetic denting on the top surface |
| Chimney cap and chase cover | Keep water out of the flue or chase | Dented chase covers that now pond water toward the flue; punctured tops; broken seams | Light dings that still shed water |
| Gutters and downspouts (only if the form reaches them) | Collect and move water | Sections pitched backward, dents that hold water or overflow, split seams, crushed downspouts that restrict flow, pulled hangers | Dings on an otherwise draining run |
Write drip edge as its own item with its own photos; our drip edge vs. gutter apron guide covers the distinction if your market uses both.
Frontera’s field guide flags one more point on painted or coated metals: denting alone usually isn’t enough, but coating or seam damage confirmed by testing is a different fact. Hail that cracks the finish can expose the base metal, which is a durability question, not a looks question. Document it close up and let a qualified professional speak to the testing.
The documentation standard
“Hail dings” is what the Combs file said, and that phrase lost. Your file should say what the ding does. For each metal component:
- Close-ups with scale. A tape or scale card in the frame, the dent depth measured where you can, and the location marked on the roof diagram.
- Context shots. The whole component and how it ties into the shingles, wall or gutter, so a desk adjuster can see where water goes.
- The water path. This is the shot most files are missing. A valley with a pocket that ponds, a drip edge flange that now points at the fascia, a step flashing leg lifted off the wall. Where it is safe and the homeowner agrees, a light water test with video shows the path better than any caption.
- Interior and attic evidence. Staining, wet sheathing, or daylight at a penetration below the damaged component.
- The manufacturer’s words. Installation instructions for valleys, flashings and vents describe what the part is supposed to do. Quoting them ties “functional” to a published standard instead of your opinion.
- A short written note per component. One or two sentences: what you observed, what it does to water or airflow, and why the part can’t be straightened or resealed.
Our photo requirements checklist and 2026 hail season playbook cover the rest of the shot list.
None of this turns cosmetic damage into functional damage. It makes sure that when the damage is functional, the file says so in the definition’s own terms.
Where the roofer’s job ends
A cosmetic exclusion fight has two layers, and only one belongs to you.
The first layer is facts: what is damaged, how, and what it costs to repair or replace to the manufacturer’s specifications. That is your inspection and your scope, and it’s what EOD writes into the supplement.
The second layer is coverage: whether a metal-roof exclusion reaches valley metal on a shingle roof, or whether “to the same extent” means the same as “intended function.” Those are questions for the carrier and, if the homeowner wants to contest them, for their agent, a licensed public adjuster, or an attorney. In many states, a roofer arguing coverage for the homeowner is public adjusting. Our breakdown of the roofer vs. public adjuster line by state shows where that line sits.
Quick answers
Can a metal-roof cosmetic exclusion apply to a shingle roof?
In Combs v. CSAA (W.D. Okla., Sept. 15, 2026), the court said yes for that policy, holding the exclusion reached valley metal because it applied to roof coverings that are metal. Other policies and other courts may read different wording differently.
What makes damage “functional” instead of cosmetic?
It depends on the policy’s definition. Common tests are water penetration, failure to perform the intended function, or not working “to the same extent” as before. Document what the damaged part now fails to do.
Does a cosmetic exclusion cover gutters and siding?
Only if the form says so. Some exclusions are limited to roof coverings; others list siding, gutters, windows and doors, or all exterior surfaces. Read the definitions section.
Should the roofer argue that the exclusion doesn’t apply?
No. The roofer documents damage and writes the scope. Coverage disputes belong to the carrier, and to the homeowner’s agent, public adjuster or attorney if the homeowner contests them.
The takeaway
Combs didn’t create a new exclusion. It showed how far an old one reaches when the definitions are broad and the file is thin. The inspector saw the damage; what was missing was a few photos and a sentence on whether the valley still carried water.
So add “cosmetic exclusion: which components, which functional test” to your dec page review, and ask of every metal component: what does this dent do? If the answer is “nothing,” move on. If it’s “it sends water under the shingles,” make sure the supplement says so, with the picture to prove it. Our guide to writing a roofing supplement covers how to put that into line items.
Sources: Property Insurance Coverage Law Blog, “Cosmetic Damage Exclusions Are Becoming Anything but Cosmetic” (Sept. 24, 2026); Combs v. CSAA General Insurance Co., No. CIV-25-805 (W.D. Okla. Sept. 15, 2026); Insurance Business, “Court revives Cannon Falls hail claim, narrows Hanover cosmetic damage exclusion” (July 30, 2026); Cannon Falls Area Schools v. Hanover American Insurance Co., No. 25-3315 (8th Cir. 2026); Frontera Claims, “Cosmetic Damage Exclusions” field guide; Insurance.com, “What is a wind and hail cosmetic damage exclusion?” (updated June 9, 2026). Exclusion wording varies by carrier, form and state. This post is general information for roofers, not legal advice; the policy in front of you controls.
Got a claim where the metals came off the estimate as “cosmetic”? EOD’s roofing supplement services read the policy, write every component your photos support, and follow the supplement through with the carrier: 10% of the increase, no increase, no fee, no minimums. Send us a claim.
