CJ-2025-5164 - Miss Helen's Private Schools, Inc. v. State Farm Fire & Casualty Company

What's This Case About?

Let’s be real: a private school is suing State Farm for underpaying a storm damage claim by $93,661.75 — and then topping it off with a demand for $75,000 in punitive damages because, allegedly, the insurance giant looked at a roof, saw storm damage, and said, “Nah, that’s just old age.” This isn’t just a fight over shingles and ceiling tiles — this is David vs. Goliath, with hail.

Miss Helen’s Private Schools, Inc. isn’t some chain of glossy prep academies with polo-shirted kids sipping kombucha between AP classes. It’s a small, Oklahoma-based private school, the kind that probably has a “World’s Best Teacher” mug in the break room and a principal who knows every student by name — and likely by their parents’ credit score. They own property on South Mingo Road in Tulsa, a building that, like most school buildings, probably hasn’t seen a full renovation since the Clinton administration. But they did pay their insurance premiums — religiously — to State Farm, one of the biggest insurance companies in America, the folks whose jingle you’ve hummed while debating whether to file a claim for a dinged bumper.

On May 21, 2024, a wind and hailstorm rolled through Tulsa like an angry ex with a grudge. The kind of storm that turns patio furniture into projectiles and leaves your car looking like it went ten rounds with Mike Tyson. Miss Helen’s took a hit. Roof damage. Ceiling tiles raining down like sad confetti. The whole shebang. So, like any responsible policyholder, the school did the right thing: they called State Farm, filed a claim (number 36-81D4-21W, because nothing says drama like a 12-digit claim code), and waited.

State Farm sent an adjuster — not until March 2025, which is, uh, nine months later? That’s not a response time, that’s a gestation period. When the adjuster finally showed up, they took one look at the roof and decided the damage was limited to eight shingles, ten turtle vents (which are real, by the way — they’re roof vents that look like tiny armored reptiles), ten rain caps, and 200 ceiling tiles. Their estimate? A grand total of $2,906.12. That’s less than the deductible on some people’s car insurance.

Meanwhile, the school had already hired its own contractor, because when you’re running a school and your roof is literally leaking onto math textbooks, you don’t have time to wait for an insurance company’s version of a house call. Their contractor looked at the same building and said, “Yeah, this roof is done. You need a full replacement — plus interior repairs.” His estimate? $93,661.75. That’s not a repair bill. That’s a mortgage down payment in some parts of Oklahoma.

So Miss Helen’s did what any frustrated, underpaid, and slightly soggy business would do: they submitted a formal proof of loss in July 2025, backed by photos and contractor estimates, demanding the full amount. State Farm asked for more photos — fair enough — and then responded by saying the damage looked like “wear and tear,” not storm damage. Translation: “Your roof was already junk. We’re not paying.”

Here’s where it gets spicy. According to Oklahoma law — specifically 36 O.S. § 1250.7 — if an insurer denies a claim, they’re supposed to tell you. In writing. With reasons. State Farm, the filing claims, never sent a formal denial. They just… ghosted the full amount. Paid $2,906.12. Left the school holding a $90,000 repair bill and a classroom full of damp kids.

So now Miss Helen’s is in court, and they’re not just mad — they’re strategically furious. Their lawsuit has two main claims, and they’re the one-two punch of insurance disputes: Breach of Contract and Bad Faith.

First, the breach of contract part is simple: “We paid our premiums. You promised to cover storm damage. The storm came. The damage happened. You didn’t pay. That’s a broken promise.” No mystery there. But the bad faith claim? That’s where things get legally juicy. In insurance law, companies don’t just have a contract — they have a duty to treat their customers fairly. That means investigating claims honestly, not lowballing people because it’s cheaper, and not dragging their feet for months on end. Miss Helen’s is alleging State Farm didn’t just make a bad estimate — they intentionally underpaid, ignored evidence, delayed the process, and violated state law by not issuing a formal denial. If proven, that’s not just a business disagreement — it’s a potential slap on the wrist with a $75,000 glove.

And that’s the kicker: Miss Helen’s isn’t just asking for the $93,661.75 they say they’re owed. They’re also demanding over $75,000 in punitive damages — money meant to punish State Farm, not compensate the school. They want attorney fees, court costs, interest, and a jury trial, because apparently, they want this aired out in public like a reality TV showdown.

Now, is $93,661.75 a lot for a school? Absolutely. For a private institution likely operating on tight margins, that’s payroll for a teacher, or new textbooks, or not having to ask parents for yet another “facility improvement” donation. It’s not chump change. But for State Farm? That’s less than a rounding error. In 2023, State Farm paid out over $40 billion in claims. $93k is what they probably spend on coffee for their adjusters.

So what’s the most absurd part? It’s not the nine-month delay. It’s not even the eight-shingle theory of structural collapse. It’s the sheer audacity of looking at a school — a place of learning, of child safety, of future-citizen cultivation — and saying, “Yeah, your roof is destroyed, but we’re only paying for the turtle vents.” It’s the image of some corporate claims analyst in a cubicle, squinting at a photo of a shredded roof and declaring, “Looks like normal aging to me.”

Are we rooting for Miss Helen’s? You bet we are. Not because we hate big insurance companies (okay, maybe a little), but because this is what happens when a system designed to protect people starts protecting profits instead. A school shouldn’t have to sue its insurer just to keep the rain out of the science lab. And if State Farm really did ignore clear damage, delay for months, and then pay pennies on the dollar without a proper denial? Then yeah — let’s have that jury trial. Bring the photos. Bring the contractors. Bring the turtle vents.

Because in the courtroom of public opinion, State Farm just got hit with a hailstorm of its own making.

Case Overview

Jury Trial Petition

Jurisdiction

District Court, Oklahoma

Filing Attorney

Ashley Leavitt

HOLBROOK LEAVITT & ASSOCIATES, PLLC

Relief Sought

$193,662 Monetary

$75,000 Punitive

Plaintiffs

Miss Helen's Private Schools, Inc. business
Rep: Ashley Leavitt, OBA #32818

Defendants

State Farm Fire & Casualty Company business

Claims

#	Cause of Action	Description
1	Breach of Contract	Plaintiff claims Defendant breached insurance contract by underpaying storm damage claim
2	Bad Faith	Plaintiff claims Defendant acted in bad faith by denying and underpaying storm damage claim

Petition Text

1,139 words

IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA MISS HELEN'S PRIVATE SCHOOLS, INC., ) Plaintiff, v. ) STATE FARM FIRE & CASUALTY COMPANY, ) Defendant. PETITION COMES NOW, the Plaintiff, Miss Helen’s Private Schools, Inc., (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, Miss Helen’s Private Schools, Inc., is an Oklahoma corporation with its owners/members all being citizens of the State of Oklahoma. Plaintiff, now, and at all times relevant hereto, 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 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 Plaintiff, there was in full force and effect a policy of insurance issued by State Farm to Plaintiff, bearing the policy number 96AJA4139 (hereinafter referred to as the "Policy"). 7. Under the terms of the Policy, Defendant agreed to insure Plaintiff against certain losses to Plaintiff's property located at 4849 S. Mingo Rd. Tulsa, OK 74146, (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, Plaintiff's Property was damaged as a result of a wind/hailstorm. 9. The Policy insured the Property against the type of loss and damage suffered. 10. Plaintiff reported the loss to Defendant; Defendant acknowledged the same and assigned claim number 36-81D4-21W to this loss (hereinafter referred to as the "Claim"). All other conditions precedent to entitle Plaintiff to coverage and benefits under the Policy have been satisfied. FIRST CLAIM FOR RELIEF (Breach of Contract) 11. Plaintiff incorporates all allegations set forth above as though fully set forth herein. 12. The Policy constitutes a valid and binding contract between Plaintiff and Defendant. 13. Plaintiff timely paid Defendant the owed Policy premiums. 14. In exchange for the Policy provisions, State Farm agreed to provide Plaintiff insurance coverage to Plaintiff's Property. 15. On or about May 21, 2024, when the above-referenced insurance policy was in full force and effect with all premiums paid, Plaintiff suffered a covered loss: storm damage. 16. Plaintiff has 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 Plaintiff being paid less than what it was owed under the terms and conditions of the insurance policy issued by the Defendant. The acts and omissions of the Defendant in the investigation, evaluation, delay, and payment of Plaintiff’s claim were unreasonable and constitute a breach of contract for which contractual damages are hereby sought. 18. Plaintiff remains damaged in an amount not less than $93,661.75 for the actual damages to their property caused by the storm. 19. Plaintiff has been forced to expend money for court costs and litigation for which it should be compensated. 20. Pursuant to 12 O.S. § 2008(A)(2) and the above facts and circumstances, Plaintiff is entitled to relief under Oklahoma statutory and common law. SECOND CLAIM FOR RELIEF (Bad Faith) 21. Plaintiff incorporates all allegations set forth above as though fully set forth herein. 22. Plaintiff timely filed a claim with State Farm. 23. State Farm sent an adjuster to inspect the Property on or about March 17, 2025. 24. State Farm then wrote an estimate for damage to eight (8) individual shingles, ten (10) turtle vents, ten (10) 8” rain caps, and two hundred (200) R&R suspended ceiling tiles. The estimate resulted in a net payment of $2,906.12. 25. Plaintiff’s contractor inspected the Property and noted widespread storm damages requiring a total roof replacement, as well as interior repairs, and that the cost to repair the damage totaled at least $93,661.75. 26. On July 15, 2025, Plaintiff submitted a proof of loss pursuant to 36 O.S. § 3629 based on their contractor’s estimate. 27. Defendant responded by requesting photos showing the scope of damages to warrant a roof replacement. Plaintiff provided the contractor’s photos three days later. Defendant stated the photos showed wear and tear and not hail damage. 28. Defendant failed to provide a written denial of the claim to Plaintiff in violation of 36 O.S. § 1250.7. 29. Defendant refused to acknowledge the covered loss and refused to pay Plaintiff the full amount of the covered loss owed under the Policy. 30. The acts and omissions of Defendant were in direct breach of its duty to deal fairly and in good faith with its insured, Plaintiff, and done for Defendant’s own financial benefit. 31. Defendant intentionally underpaid, delayed, and failed to investigate Plaintiff’s claim. The conduct of the Defendant, in the lack of investigation, evaluation, and payment of Plaintiff’s 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 Plaintiff’s claim for which extra-contractual damages are hereby sought. DAMAGES 32. Plaintiff incorporates all allegations set forth above as though fully set forth herein. 33. Defendant’s actions have caused Plaintiff to suffer mental pain, mental anguish and suffering, anxiety, embarrassment, and loss of reputation in an amount to be determined. 34. Defendant’s conduct with respect to Plaintiff’s 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 insured, Plaintiff. WHEREFORE, premises considered, Plaintiff moves 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 Plaintiff should be awarded a sum not less than $93,661.75 in actual damages; a sum in excess of $75,000.00 for consequential damages as a result of Defendant's breaches; a sum in excess of $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 Plaintiff