Accordingly, “[o]nce a plaintiff has identified a policy or custom, she ‘must show that the municipal action was taken with the requisite degree of culpability, and must demonstrate a direct causal link between the municipal action and the deprivation of federal rights.'” Abran v. City of Philadelphia, No. 18-CV-1107, 2020 WL 6781938, at *12 (E.D. Pa. Nov. 17, 2020) (quoting Vulcan Pioneers of New Jersey v. City of Newark, 374 Fed.Appx. 313, 317 (3d Cir. 2010)). If the policy does not facially violate federal law, “causation can be established only by ‘demonstrat[ing] that the municipal action was taken with ‘deliberate indifference' as to its known or obvious consequences.'” Id.
See Marvel v. Delaware County, No. 07-cv-5054, 2009 WL 1544928, at *17 (E.D. Pa. June 2, 2009) (granting defendant's motion for summary judgment where plaintiff's expert report proffered to prove causation included only “conclusory opinions without explicit factual foundation” (internal citations and quotations omitted)); see also Abran v. City of Philadelphia, No. 18-cv-1107, 2020 WL 6781938, at *14 (E.D. Pa. Nov. 17, 2020) (“[C]onclusory allegations . . . cannot defeat summary judgment.”). Accordingly, Covenant is unable to show that the Collapse is covered by the Policy's windstorm exception, so the Court grants Westminster's motion as to this exception.
v. City of Philadelphia, Civ. A. No. 18-cv-1107, 2020 WL 6781938, at *4 (E.D. Pa. Nov. 17, 2020) (citing Galena v. Leone, 638 F.3d 186, 196 (3d Cir. 2011)).