Doyle bought $18 million of supposedly rare wine from a fraudster who filled the bottles with worthless wine and affixed false labels.  Doyle insured the wine under a valuable possession property insurance policy.  He sued the insurer trying to recoup his loss.  Held, the policy provides no coverage since there was no damage to the wine.  Property insurance covers loss from physical damage to property, not a loss in market value of undamaged property due to causes other than damage, such as fraud.

California Court of Appeal, Fourth District, Division 3 (Moore, J.); March 7, 2018; 2018 WL 1177929