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Insurers Take Heed: South Carolina Law Does Not Require Apportionment of Punitive Damages

In a significant but not entirely novel ruling, the South Carolina Supreme Court recently held that South Carolina law does not require the pro rata apportionment of punitive damages between damages sustained for bodily...more

Reconsideration of Interlocutory Orders - The breadth and limitation of Federal Rule of Civil Procedure 54(b)

A district court may revise “any order or other decision…that adjudicates fewer than all the claims or the rights and liabilities of fewer than all the parties…at any time before the entry of a judgment adjudicating all the...more

Can a Third Party Seek a Declaration of an Insurer's Duties Under Its Policy?

“Be careful what you ask for in your declaratory judgment action” could have been an appropriate subtitle....more

Insurer's Successful Declaratory Judgment Action Provides a Refresher on Insurable Interest

It is a basic rule of law - one cannot insure, for his own benefit, the property of another. Recovery under an insurance policy requires proof of an insurable interest in the subject property at the time the policy is...more

Amount in Controversy for Diversity Jurisdiction: How to Determine When Damages Are Not Clearly Stated

Diversity jurisdiction exists when there is complete diversity of citizenship between the parties and the amount in controversy exceeds $75,000. Generally, the amount in controversy articulated in Plaintiff’s complaint is...more

The Evolution of Ripeness Affords Additional Opportunities for Declaratory Judgment Actions

In Colony Insurance Company v. Hucks Pool Company, Inc., et al. (February 15, 2018), based only upon a demand letter to Hucks from a claimant, Colony filed a declaratory judgment action that sought a determination whether it...more

Not Every Refusal to Provide Coverage Equals Bad Faith

A complicated and interesting factual history, along with a number of actions, including an earlier one for declaratory judgment, resulted in a thoughtful and reasoned opinion of the United States District Court for South...more

Statutory Construction is Powerful

The Court Interprets “Due Date” Under a Premium Service Agreement - The tools of statutory construction are powerful. In interpreting statutory language, words are generally given their common and ordinary meaning. The...more

Who Is Insured, What Is Insured and Why Makes a Difference

What do the Moody Blues and an insurance policy have in common? It boils down to this: Say what you mean and mean what you say. The District Court of South Carolina recently reminded us of the importance of the terms of...more

An Insurance Contract is Still a Contract - And How That Impacts Voluntary PIP Coverage

In two recent opinions, the SC Court of Appeals reminded readers that parties are free to contract as they see fit, as long as the contract provisions at issue are not contrary to public policy or a statutory prohibition. It...more

Bad Faith – Another Angle

In August 2011, Jeffrey Vanderhall was riding his bicycle when he was hit by a car and seriously injured. It is now six years, three courts and two bad faith attempts later... To describe the procedural history of this...more

All that Glimmers is Not [Insurance Agency] Gold

Diversity jurisdiction requires complete diversity among plaintiffs and defendants. While it is difficult for a defendant to remove a case with a nondiverse defendant, removal can be accomplished through the doctrine of...more

Ripeness: A Question of Subject Matter Jurisdiction - Allied World Surplus Lines Insurance Company v. Blue Cross and Blue Shield...

Addressing a contractual requirement to exhaust Alternative Dispute Resolution (ADR) prior to commencing litigation, the United States District Court for the District of South Carolina chose to forge its own path, rejecting...more

UIM Claims – Still No Bad Faith for Refusal to Settle, But….

South Carolina has never recognized a bad faith cause of action based upon the failure of an underinsured (UIM) carrier to settle a UIM claim. Maintaining the established precedent, the United States District Court recently...more

Another Assault – Another Exclusion

2017 is steadily becoming the year of the assault in South Carolina. Founders Insurance Company v. John Hamilton a/k/a Jim Hamilton, individually and d/b/a Aces High Club, Aces High Club and Kenneth Weatherford, 2017 WL...more

Harleysville Revisited - What We Know Now

In January, the SC Supreme Court issued its original opinion in Harleysville Group Insurance, a Pennsylvania Corporation v. Heritage Communities, Inc, a South Carolina Corporation; Heritage Magnolia North, Inc., et al. and...more

When an Assault Really Is an Assault... A Sequel

Jesse Bass was a guest at Henry’s Sports Bar in December 2012, when the bouncer struck him in the head with such force that he was knocked unconscious and suffered serious brain injury. Bass brought an action against Henry’s,...more

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