The appraisal clause of a homeowner's insurance policy was at the center of a case in which the plaintiffs sought more than $540,897 for their home when it was destroyed by a propane gas explosion.

In Woodworth et ano v. Erie Insurance Co., the U.S. District Court for the Western District of New York ruled the insurance company was not obligated to engage in the appraisal process since the amount of loss attributable to replacing the plaintiffs' home could not be determined until the replacement of the house was actually completed.