Six Bits or Bust: Insurance Litigation Over the 1906 San Francisco Earthquake and Fire

Abstract

Most histories of the 1906 San Francisco earthquake and fire recount the disputes that arose between insurance companies and insureds over whether the losses resulted from the insured fire or the uninsured quake. These studies emphasize the public pressure on the companies and the ensuing payouts. However, the issue was the subject of over thirty reported cases in California, federal and foreign courts, in which the insurance companies recorded some victories. This article describes and analyzes the court decisions and illustrates their immediate importance, as they determined the pace at which the city was rebuilt. The article also confirms the longer term impact of these cases, as they address whether covered perils such as fire, stemming from excluded perils such as earthquakes or floods, are nonetheless insured.

Keywords: 1906 San Francisco earthquake, fire insurance, ensuing loss, concurrent causation