An insured's waterbed broke while being filled, causing considerable water damage to other property to which the policy applied. Claim made under policy coverage for "accidental discharge or overflow of water...from within a household appliance" was denied by the insurer. In the course of legal action, the insurer appealed a trial court determination that the waterbed was an appliance and that coverage was applicable.

The appeal court expressed the opinion that a waterbed was not a household appliance but, rather, an item of furniture. It found the common understanding of "household appliance" to be "a household device that does work or performs a task, such as a washer, dryer, vacuum cleaner or toaster."

In response to the insured's emphasis on the fact that the leak was generated from the plumbing system, discharges from which were covered, it was clear that "the leak emanated from the waterbed itself, which is not a part of the plumbing system."

The trial court judgment was reversed in favor of the insurance company and against the insured.

(WEST AMERICAN INS. CO., Appellant v. LOWRIE, Appellee. Florida District Court of Appeal, Third District. No. 91-2975. June 9 1992. CCH 1992 Fire and Casualty Cases, Paragraph 3751.)