CJ-2026-978 - Chris Adolph v. State Farm Fire and Casualty Company

What's This Case About?

Let’s get one thing straight: State Farm, the folks in the red bowtie who promise to be “like a good neighbor,” are now being sued for allegedly acting like the worst neighbor—dragging their feet, lowballing a claim, and forcing a couple to hire a lawyer just to get their roof fixed after a hailstorm. And not just any roof. We’re talking about a full-on, total roof replacement that State Farm eventually admitted was necessary—a year after the storm, and only after the homeowners’ contractor called them out for missing basically the entire problem. That’s like showing up to a fire with a squirt gun, then pretending you didn’t see the flames until someone hands you a fire extinguisher and says, “Dude, look up.”

Meet Chris and Mariia Adolph—a married couple living in Tulsa, Oklahoma, where hailstorms hit like nature’s own personal vendetta. They own a home at 9932 S. 78th E. Ave., pay their insurance premiums like responsible adults, and—get this—actually read their policy. Shocking, we know. Their insurer? None other than State Farm Fire and Casualty Company, the insurance giant that spends millions telling us they’ve got our backs. And for a while, everything was fine. Premiums paid, policy active, life humming along. Then, on May 21, 2024, Oklahoma did what Oklahoma does: it unleashed a furious wind and hailstorm that turned roofs into Swiss cheese. The Adolphs’ home was hit. Shingles damaged. Gutters mangled. Metal valleys bent. The whole shebang. So, like any reasonable person with insurance, they called State Farm. They filed a claim—claim number 36-78X9-89B, if you’re taking notes—and waited for the cavalry to arrive.

But instead of a knight in shining armor, they got an adjuster who apparently believed in minimalism. On January 15, 2025—nearly eight months after the storm—State Farm finally sent someone to inspect the property. And what did this inspector see? According to the lawsuit, he spotted exactly six turtle vents, 215.25 feet of valley metal, and 345 feet of gutters needing work. That’s it. No mention of the shingles. No acknowledgment that the roof was basically held together by hope and duct tape. State Farm then cut the Adolphs a check for $673.02—after the deductible. Let’s be clear: that’s not enough to fix a roof. That’s enough to buy a decent lawnmower. Or, more realistically, pay for one-third of a roofing contractor’s diagnostic visit.

Unsurprisingly, the Adolphs hired a contractor of their own. And surprise, surprise—this guy actually looked at the roof. What he found was, well, a disaster. Missing shingles. Widespread damage. Structural concerns. The kind of stuff that, if left unattended, turns a roof repair into a full-house renovation when the next rainstorm decides to move in permanently. The contractor estimated the real cost of repairs: a complete roof replacement. He even did the polite thing and asked State Farm to come back and take a second look. State Farm said no. So the Adolphs did what any sane person would do when a multi-billion-dollar corporation treats your home like a game of “Spot the Damage”: they called a lawyer.

Enter Ashley Leavitt of Holbrook Leavitt & Associates, PLLC, who filed this petition with the kind of surgical precision that suggests she’s seen this movie before. On December 5, 2025—over a year after the storm—the Adolphs submitted a partial proof of loss based on their contractor’s estimate. And finally, finally, State Farm blinked. They agreed to a second inspection. January 6, 2026. Adjuster returns. Takes a real look. And what do you know? Suddenly, the roof does need to be replaced. The very same damage that was “invisible” in January 2025 was now “obviously catastrophic” in January 2026. And get this—State Farm admitted the damage had been there since the original storm. So either the roof magically deteriorated over a year of being ignored, or State Farm just didn’t bother doing their job the first time.

So why are we in court? Two reasons, spelled out in legalese but simple in spirit. First, breach of contract—which, in plain English, means: “You took our money. You promised to fix our roof if it got damaged. It got damaged. You didn’t fix it. Now pay up.” The Adolphs aren’t asking for a vacation home in the Bahamas. They’re asking for $69,531.56—the actual cost to repair what the storm broke. That’s not an outrageous sum for a full roof replacement, especially with labor, materials, and the fact that Oklahoma roofing contractors aren’t exactly working for exposure. For context, that’s less than the average cost of a new car. Less than a luxury wedding. And yet, State Farm made them sue for it.

The second claim is juicier: bad faith. This isn’t just about failing to pay—it’s about how they failed to pay. In insurance law, companies have a legal duty to treat their customers fairly. They can’t ignore evidence. They can’t delay forever. They can’t send an adjuster who only sees the shiny parts and call it a day. The Adolphs allege State Farm did all of that—and worse. They claim the insurer knew the damage was there, chose to underpay, refused a second inspection for months, and only acted when legal pressure mounted. That’s not just stingy. That’s a pattern. And in Oklahoma, when an insurer acts in bad faith, you can sue for punitive damages—meaning, “Hey, you made a ton of money by screwing us over. Now give some of it back as a lesson.”

And that’s exactly what the Adolphs want: not just their $69,531.56, but more than $75,000 in punitive damages. Plus attorney fees. Plus interest. Plus a jury trial, because they’re not about to let some insurance bean counter decide their fate behind closed doors. Is $69k a lot? For a roof, sure. But for a company that made $8 billion in profit last year? It’s a rounding error. The real cost is reputational. Because cases like this don’t just expose one bad claim—they expose a system where insurers know most people won’t fight back. They bank on frustration. On fatigue. On the fact that you’d rather live with a leaky roof than spend a year in court.

And that’s the most absurd part. The Adolphs didn’t want drama. They didn’t want a lawsuit. They wanted a roof that doesn’t leak when it rains. They played by the rules. Paid their premiums. Reported the damage. Waited. Asked nicely. Gave State Farm two whole years to do the right thing. And only when that failed—only when they were forced to hire a lawyer just to get an inspection—did the company finally admit what should’ve been obvious in 2024. This isn’t just about money. It’s about power. And we’re rooting for the homeowners, because if a couple can’t trust their insurance company after a storm, what’s the point of the bowtie?

Case Overview

Jury Trial Petition

Jurisdiction

District Court of Tulsa County, Oklahoma

Filing Attorney

Ashley Leavitt

HOLBROOK LEAVITT & ASSOCIATES, PLLC

Relief Sought

$69,532 Monetary

$1 Punitive

Plaintiffs

Chris Adolph individual
Rep: Ashley Leavitt, OBA #32818
Mariia Adolph individual
Rep: Ashley Leavitt, OBA #32818

Defendants

State Farm Fire and Casualty Company business

Claims

#	Cause of Action	Description
1	Breach of Contract	Plaintiffs allege that State Farm failed to pay for storm damages under their insurance policy.
2	Bad Faith	Plaintiffs allege that State Farm acted in bad faith by underpaying and delaying their claim.

Petition Text

1,310 words

IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA CHRIS ADOLPH AND MARIIA ADOLPH, ) ) ) Plaintiffs, v. STATE FARM FIRE AND CASUALTY COMPANY, ) Defendant. PETITION COMES NOW, the Plaintiffs, Chris Adolph and Mariia Adolph, (hereinafter referred to as "Plaintiffs"), and for their causes of action against Defendant State Farm Fire & Casualty Company, (hereinafter referred to as "Defendant" and/or "State Farm") and state and allege as follows: PARTIES 1. Plaintiff Chris Adolph, now, and at all times relevant hereto, is a citizen of the State of Oklahoma. Plaintiff Mariia Adolph is a lawful permanent resident of the United States, domiciled in the State of Oklahoma, and a citizen of Russia. Plaintiffs jointly owned real property in Tulsa County, State of Oklahoma. 2. Upon information and belief, Defendant State Farm Fire & Casualty Company, is a foreign corporation licensed to do business in Oklahoma. JURISDICTION AND AUTHORITY 3. This action is brought before this Court for the reason that it may exercise jurisdiction on any basis consistent with the Constitution of the State of Oklahoma and the Constitution for the United States. 12 O.S. § 2004(F). 4. Pursuant to 12 O.S. § 133, venue is proper in this Court as the acts complained of herein occurred in Tulsa County, Oklahoma. 5. Pursuant to 12 O.S. § 2004(F), this Court has subject matter jurisdiction over the claims asserted herein. FACTUAL BACKGROUND 6. At all times material hereto, in consideration for premiums paid by Plaintiffs, there was in full force and effect a policy of insurance issued by State Farm to Plaintiffs, bearing the policy number 36-CK-R159-2 (hereinafter referred to as the “Policy”). 7. Under the terms of the Policy, Defendant agreed to insure Plaintiffs against certain losses to Plaintiff’s property located at 9932 S. 78th E. Ave., Tulsa, OK 74133, (hereinafter referred to as the “Property”). 8. On or about May 21, 2024, when the above-referenced insurance policy was in full force and effect, Plaintiffs’ Property was damaged as a result of a known wind/hailstorm. 9. The Policy insured the Property against the type of loss and damage suffered. 10. Plaintiffs reported the loss to Defendant; Defendant acknowledged the same and assigned claim number 36-78X9-89B to this loss (hereinafter referred to as the “Claim”). All other conditions precedent to entitle Plaintiffs to coverage and benefits under the Policy have been satisfied. FIRST CLAIM FOR RELIEF (Breach of Contract) 11. Plaintiffs incorporate all allegations set forth above as though fully set forth herein. 12. The Policy constitutes a valid and binding contract between Plaintiffs and Defendant. 13. Plaintiffs timely paid Defendant the owed Policy premiums. 14. In exchange for the Policy provisions, State Farm agreed to provide Plaintiffs insurance coverage to Plaintiffs’ Property. 15. On or about May 21, 2024, when the above-referenced insurance policy was in full force and effect with all premiums paid, Plaintiffs suffered a covered loss: storm damage. 16. Plaintiffs have fully performed under the Policy and have demanded that Defendant perform; however, Defendant has refused to perform and has materially breached the Policy. 17. The acts and omissions of State Farm, in the handling of Plaintiff's claim, were unreasonable and resulted in Plaintiffs being paid less than what they were owed under the terms and conditions of the Policy issued by the Defendant. The acts and omissions of the Defendant in the investigation, evaluation, delay, and payment of Plaintiffs' claim were unreasonable and constitute a breach of contract for which contractual damages are hereby sought. 18. Plaintiffs remain damaged in an amount not less than $69,531.56 for the actual damages to their dwelling caused by the storm. 19. Plaintiffs have been forced to expend money for court costs and litigation for which they should be compensated. 20. While the Policy contains a one year "Suit Against Us" provision, Plaintiffs were unrepresented on May 21, 2025, and Defendant continued to handle the Claim with Plaintiffs past this date, including, but not limited to, performing a second inspection on or about January 6, 2026, and issuing an additional claim payment of $21,538.89. Therefore, by its behavior, State Farm has waived its one year contractual limitations period. 21. Pursuant to 12 O.S. § 2008(A)(2) and the above facts and circumstances, Plaintiffs are entitled to relief under Oklahoma statutory and common law. SECOND CLAIM FOR RELIEF (Bad Faith) 22. Plaintiffs incorporate all allegations set forth above as though fully set forth herein. 23. Plaintiffs timely filed a claim with State Farm on or about December 19, 2024, in accordance with their State Farm Policy and 36 O.S. § 1250.5(7). 24. State Farm sent an adjuster to inspect the Property on or about January 15, 2025. 25. Based on the inadequate inspection of the adjuster, State Farm estimated damages to just six (6) turtle vents, 215.25 linear feet of valley metal, and 345 linear feet of gutters. After applying Plaintiffs’ deductible, State Farm issued payment in the amount of $673.02. 26. Plaintiffs’ contractor inspected the Property and noted significant damages missed by State Farm, including, but not limited to, damaged and missing shingles. 27. Plaintiffs’ contractor requested State Farm perform a second inspection to address the missed damages, but State Farm refused. 28. With no other option, Plaintiffs hired the undersigned attorney to help recover the Policy benefits they were entitled to. 29. On December 5, 2025, Plaintiffs submitted a partial proof of loss pursuant to 36 O.S. § 3629 based on their contractor’s estimate. 30. Defendant agreed to perform a second inspection, which took place on January 6, 2026. State Farm then updated its estimate to a total roof replacement, based on damages which were present at the Property during its first inspection a year before. 31. Defendant refused to acknowledge the covered loss in a timely manner and refused to pay Plaintiffs the full amount of the covered loss owed under the Policy. 32. The acts and omissions of State Farm, in the handling of Plaintiffs’ claim, were unreasonable and resulted in Plaintiffs being paid less than what they were owed under the terms and conditions of the insurance policy issued by the Defendant. 33. The acts and omissions of the Defendant in the investigation, evaluation, delay, and payment of Plaintiffs’ claim were unreasonable. 34. The acts and omissions of Defendant were in direct breach of its duty to deal fairly and in good faith with its insureds, Plaintiffs, and done for Defendant’s own financial benefit. 35. Defendant intentionally underpaid, delayed, and failed to investigate Plaintiffs’ claim. The conduct of the Defendant, in the lack of investigation, evaluation, and payment of Plaintiffs’ claim was unreasonable, outside of insurance industry standards, and constitutes a breach of the duty of good faith and fair dealing resulting in the wrongful and bad faith denial of Plaintiffs’ claim for which extra-contractual damages are hereby sought. DAMAGES 36. Plaintiffs incorporate all allegations set forth above as though fully set forth herein. 37. Defendant’s actions have caused Plaintiffs to suffer mental pain, frustration, anxiety, embarrassment, and loss of reputation in an amount to be determined. 38. Defendant’s conduct with respect to Plaintiffs’ Claim constitutes a bad faith breach of contract, for which punitive damages should be awarded pursuant to 23 O.S. § 9.1 due to the wrongful, willful, and intentional conduct of the Defendant which was in reckless disregard of the rights of its insureds, Plaintiffs. WHEREFORE, premises considered, Plaintiffs move for a finding by the Court that Defendant State Farm Fire & Casualty Company breached its contractual duty to pay for storm damages under the valid Policy; that Defendant State Farm Fire & Casualty Company violated the duty of good faith and fair dealing; that Plaintiffs should be awarded a sum not less than $69,531.56 in actual damages; a sum for an amount less than $75,000.00 for consequential damages as a result of Defendant’s breach; sum for an amount greater than $75,000.00 for punitive damages; that an award of attorney fees, costs of litigation and interest is proper pursuant to 36 O.S. § 3629, 12 O.S. §§ 936, 940 & 942, and Oklahoma common law; and for such other and further relief as the Court may deem equitable under the circumstances. JURY TRIAL DEMANDED Respectfully Submitted, Ashley Leavitt, OBA #32818 HOLBROOK LEAVITT & ASSOCIATES, PLLC 4815 S. Harvard Ave., Ste 285 Tulsa, OK 74135 P: (918) 373-9394 F: (918) 539-0269 E: [email protected] Counsel for the Plaintiffs