State Farm Claim Documents Found To Be Non-Confidential

Court Unseals 31 State Farm Documents — Our Firm Moves to Make Them Public Record

Comanche County Judge Sheperd ruled on August 20, 2026 that 31 internal documents are not “confidential” and are not required to be filed under seal. These documents show State Farm developed hidden tactics to reduce wind and hail payments across the nation in secret — and it worked: in the first year, State Farm reduced indemnity claim payments by $1.4 billion. Click 2026-08-21 – West Response & Counter Motion with Exhibits 1-32 to see the 31 exhibits de-designated, and Exhibit 32 is Judge Sheperd’s order.

The Ruling

Whitten Burrage, the firm leading the charge with hundreds of cases against State Farm in Oklahoma, filed a Motion to De-designate 44 documents that State Farm had fought for years to keep sealed under protective orders. On August 20, 2026, District Judge Grant Sheperd of Comanche County ruled that 31 of those 44 documents were not entitled to confidential treatment. Whitten Burrage has also been retained to prosecute the State of Oklahoma’s action against State Farm alongside the Attorney General’s fantastic team.

Our Firm’s Response

The day after Judge Sheperd’s order, our firm filed a Response Motion and attached all 31 de-designated documents into the public record as evidence that the State Farm scheme is supported by discovery produced by State Farm and the captive State Farm agents are aware they are selling illusory coverage. That filing means the documents are no longer confined to litigation files — they’re now accessible for anyone to review.

What the Documents Show

The unsealed records lay out an internal, company-wide effort to reduce wind and hail claim payments — developed and rolled out without policyholders’ knowledge. The documents include internal savings metrics and payment-reduction targets tied to roof and storm-damage claims.

1. It started as a “biggest bucket of opportunity.” Internally, State Farm identified full roof replacements as the single largest area where it could cut costs. One executive, Nicole Manduca, wrote plainly that this “biggest bucket” meant savings on what the company pays out to policyholders. (Ex. 3-4). A 2020 planning document put a number on it: roof claims made up 57% of what State Farm was paying out — making it the company’s top target. (Ex. 5).
2. They built a “playbook” and rolled it out nationwide. Starting with a “kickoff” in Dallas County, Texas in June 2020, the “tactics” expanded to all of Texas by December, then to every state by the end of that year. (Ex. 30). The documents lay out the specific tools used to get adjusters to approve fewer full roof replacements and more “repairs” instead:
   • A “Roof Skills Review” and mandatory refresher training
   • A training module called “Art of the Conversation” — essentially, a script to help adjusters and agents deliver bad news to customers without changing the actual insurance policy
   • “Haag Refresher”
   • Extra manager sign-off required before a roof replacement could be approved — but not before a claim was denied or downgraded to a repair
   • Weekly tracking of how often roof-replacement decisions were being “overturned” to repairs instead
   • A dedicated internal team — the “Hail Reconciliation Unit” — whose job was to review and reverse roof-replacement recommendations

   Ex. 30. The duty of good faith and fair dealing requires that insurance companies cannot employ tactics to arbitrarily reduce coverage, yet State Farm engaged in these tactics regardless.

3. They measured it like a sales campaign. Executives discussed “how we’ll know the tactics are working” and tracked the ratio of full roof replacements to partial repairs. (Ex. 2). According to the documents, that ratio was cut by more than half after the rollout. (Ex. 6). One executive, Tom Moss, did the math out loud in an email: each percentage-point drop in approvals was worth roughly $78.8 million a year, based on an average savings of about $15,769 per denied or downgraded claim. (Ex. 7).
4. They bragged about the results. An internal email credits the roof tactics with a $1.4 billion drop in claims payouts in just the first year. (Ex. 6). One executive described a new internal tracking dashboard as a “silver platter” handed to the team running the program. (Ex. 8).
5. There was assistance from outside consulting to make the numbers look legitimate. State Farm hired Accenture to help develop industry benchmarks suggesting insurers overpay on wind and hail claims — benchmarks built to justify the internal cost-cutting rather than to reflect independent, objective standards. (Ex. 10, Ex. 30).
6. State Farm worked with Haag to use a hidden definition of damage, which is missing from State Farm’s policy. Haag wrote a white paper in 2006, which defined functional damage as: “Functional damage to any roofing is defined as diminution in its water-shedding capability or reduction in the expected long-term service life of the material.” State Farm’s operational guidelines, on Section C, Composition Roofs, State Farm trains its adjusters that “damage occurs to roof coverings when water shedding ability or the life expectancy of the material is reduced.” (Ex. 26). That is the same definition provided by Haag, but is completely missing from State Farm’s policies. Exhibit 27 shows that State Farm required all of its claim handlers and team managers must watch at least 2 hours each year and new claim handlers must have 5.5 hours of Haag training videos.
7. State Farm’s own agents were sounding the alarm the whole time. Hundreds of agents complained because they witnessed firsthand how wind and hail claim handling changed drastically but the policy did not change at all. A State Farm agent, Tracy Haus, emailed company leadership directly, including the CEO and CFO, warning that the company’s reputation was collapsing because of how roof claims were being handled. (Ex. 17). She wrote that customers were being lowballed, that adjusters were being pushed to write repair estimates instead of replacements even when replacement was clearly warranted, and that even competitors known for bad claims service — like Allstate — now had a better reputation than State Farm in some markets. Other internal documents describe agents as “distrustful” of the company and note a “larger than normal number of complaints.” (Ex.’s 18, 19, 20, 21). Leadership’s response, per the documents, was to keep running the same tactics causing agents, contractors and insureds complaints. (Ex.’s 6, 13, 14). State Farm engaged in training the agents to have harder conversations with the “Art of the Conversation,” which helped agents have “tougher conversations” when “we are unable to extend coverage or only partial coverage.” (Ex. 9). State Farm even had an Oklahoma call with all the captive agents to discuss wind and hail coverage in 2020. (Ex. 24).
8. There was even a repurposed “Fix Profit Task Force” discussing claims. Internal emails show a group originally focused on profit strategy was repurposed to meet weekly specifically to discuss claims-handling numbers — a detail that undercuts the industry’s usual defense that claims departments are walled off from profit pressure. (Ex. 14).

A 2020 “Prioritized Tactics” playbook lays out the rollout timeline: a kickoff in Dallas County, Texas in June 2020, expansion across Texas that December, and expansion to all states by December 17, 2020. The listed tactics include roof skills reviews, HAAG refresher training, team-manager review of roof-replacement recommendations (but not denials), and weekly monitoring of overturned recommendations. (Ex. 30.) A related “Hail Reconciliation Unit” is described as existing specifically to overturn full-replacement recommendations and track the resulting reductions in coverage. (Ex. 31.)

Why this matters (the “so what”)

Insurance regulators and courts have generally held that a claims department is supposed to evaluate what’s owed based on the policy and the damage — not based on internal savings targets. These documents show State Farm running its wind and hail claims process more like a cost-cutting sales campaign, complete with quotas, tracking dashboards, and internal messaging control — while telling customers nothing had changed about their coverage.

“Internal State Farm documents, unsealed for the first time in a court case, show company leadership built and tracked a nationwide program to reduce roof-damage payouts — bragging in 2021 about saving $1.4 billion in a single year — even as its own agents warned executives the company’s reputation with customers was collapsing.” – Senior Partner, Reggie Whitten

The duty of good faith and fair dealing that Oklahoma law requires all insurance companies to owe its insureds means insurance companies must be fair to you. Under Oklahoma law, the duty of good faith and fair dealing in every insurance contract requires insurance companies to treat their insureds fairly, cannot offer less than a claim is worth, and must evaluate the claim timely and thoroughly on its individual merits. Milroy v. Allstate Ins. Co., 2007 OK CIV APP 6, ¶18, 151 P.3d 922; Newport v. USAA, 2000 OK 59, ¶ 15, 11 P.3d 190; Christian v. American Home Assur. Co., 1977 OK 141, ¶ 12, 577 P.2d 899; 36 O.S. § 1250.5. 

Why This Matters

These filings are part of a much larger legal fight playing out across Oklahoma, where homeowners and the state Attorney General have raised similar concerns about how major insurers handle wind and hail claims after severe storms. For the families involved in these cases, the newly public documents may offer the clearest evidence yet of how their claims were decided — and why.

To learn more, see Reggie Whitten and Hannah Whitten’s interview below.

This post reflects publicly filed court documents and statements made by counsel in ongoing litigation. State Farm disputes the allegations described above. Whitten Burrage looks forward to proving these allegations at trial.