No. 25-1121 (7^th Circuit July 13, 2026)

In Gibson v. Chubb National Insurance Co., Wesley Gibson suffered a catastrophic fire at Pine Manor, a large mansion that began as a family vacation home but had evolved into a commercial lodging and events venue. Although Gibson continued to insure it under a homeowner’s policy, Pine Manor generated substantial lodging revenue and hosted corporate retreats, weddings, and other events.

Chubb paid the full $8.75 million limit for the mansion itself but limited coverage for most of its contents to $25,000 because the homeowner’s policy classified property “used to conduct” Gibson’s business as business property subject to that sublimit. Gibson sued for the full $3.5 million contents limit. The Seventh Circuit affirmed summary judgment for Chubb, concluding that the furnishings, artwork, antiques, and decorations accessible to guests were overwhelmingly used to further Pine Manor’s lodging and events business.

Takeaways:

• Property originally purchased for personal use can become “business property” when it is later used to conduct a business. The court emphasized that the relevant question was how the contents were being used when the policy was in effect and the loss occurred—not who bought them or why they were originally purchased.
• Although Gibson’s family still occupied Pine Manor roughly 70 nights per year, the guests had broad access to its furnishings and artwork, which were part of the experience marketed to paying customers. The court therefore found the contents were overwhelmingly used for business purposes.
• The court noted that Chubb had warned Gibson’s insurance broker in 2017 of a potential “large gap in coverage” and recommended commercial property insurance, but Gibson continued renewing his homeowner’s policy. The resulting $25,000 business-property limitation was enforced as written. The homeowner’s policy created a major coverage gap when the residence became a commercial operation.