News & Analysis as of

Pleading Standards Insurance Litigation

Carlton Fields

Florida Appeals Court Decisions Week of May 5 - 9, 2025

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U.S. Eleventh Circuit Court of Appeals - Jones v. Ceinski - qualified immunity - Otto Candies v. Citigroup - RICO, fraud, conspiracy - Berrocal v. US Att’y Gen - standing, international treaty - Maglana v....more

Faegre Drinker Biddle & Reath LLP

Court Dismisses TCPA Case Due to Failure to Plausibly Allege That the Defendant Made the Calls at Issue

A recent decision out of the Eastern District of Virginia, Matthews v. Senior Life Ins. Co., provides a helpful reminder that TCPA complaints do not satisfy Rule 8’s pleading standard if they do not plausibly link the...more

Ropes & Gray LLP

Plan Sponsors Beware: The U.S. Supreme Court Just Eased Requirements to File ERISA Prohibited Transaction Suits

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Many sponsors and fiduciaries of ERISA retirement plans had been hoping that the U.S. Supreme Court’s opinion in Cunningham v. Cornell University (No. 23-1007) would articulate new pleading standards that would slow the...more

Cozen O'Connor

Fifth Circuit Reaffirms Appraisal and Bad Faith Jurisprudence as Policyholders Continue to Probe for Opportunities

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The United States Court of Appeals for the Fifth Circuit upheld a summary judgment granted to the insurer over a policyholder’s argument that payment of an appraisal award and interest may extinguish an insurer’s liability...more

Carlton Fields

Eleventh Circuit Affirms Dismissal of First-Party Property Complaint for Failure to Meet Pleading Standard

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The Eleventh Circuit Court of Appeals, in M&M Sisters LLC v. Scottsdale Insurance Co., affirmed the district court’s dismissal of an insured’s third amended complaint against its insurance carrier for failure to state a claim...more

Jenner & Block

Is There a Limit to Insurer Unwillingness to Cover Claims for Unsolicited Marketing Communications? Two Decisions by the Seventh...

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Among the many unusual aspects of 2021 is that the same insurance company was before a federal appellate court on two separate but contemporaneous cases – one in which the insurer was asserting a lack of insurance coverage...more

Hinshaw & Culbertson LLP

The LHD/ERISA Advisor: Failure to Plead "Special Relationship" Results in Dismissal of Breach of Fiduciary Duty Claim

In Tifer v. New York Life Ins. Co., 2019 U.S. Dist. LEXIS 119702 (N.D. Fla. July 18, 2019), a U.S. District Court for the Northern District of Florida dismissed a state law claim for breach of fiduciary duty against an...more

Cozen O'Connor

Defending Institutional Bad Faith Claims, Part II – Focusing on Plausibility

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In Part I of this series, we discussed institutional bad faith and best practices for insurers to minimize the risk of these costly and intrusive lawsuits. In Part II, we will focus on cutting discovery off at the...more

Carlton Fields

Break Out Your Crystal Ball: New York’s First Department Relies on Policy’s Mitigation Provision as Support for Allegation That...

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An insured sought coverage under its commercial property insurance policy for property damage incurred after construction work was performed in an adjoining building. ...more

Farrell Fritz, P.C.

Are There Heightened Pleading Requirements When Alleging Consequential Damages Against an Insurer in a Coverage Dispute? “No”,...

Farrell Fritz, P.C. on

Are “consequential damages” available on contract claim against an insurer in an action brought by an insured for breach of a commercial liability policy? In D.K. Prop., Inc. v. National Union Fire Ins., a recent case out of...more

Farrell Fritz, P.C.

“Unnecessary and Inappropriate”: The declaration no one wanted

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Your client wants to recover damages for breach of contract and demands that you assert as many causes of action as possible. In addition to the breach cause of action, you consider a declaratory judgment claim, right? ...more

Farrell Fritz, P.C.

Don’t Forget To Calendar Your Deadlines – Especially The Statutory Ones!

Farrell Fritz, P.C. on

If you commence an action by way of summons with notice, you must bear in mind the strict time limitations imposed by CPLR 3012(b). When the other party timely serves a written demand for a complaint, you have exactly twenty...more

Cozen O'Connor

“Low-Ball” Settlement Offer On Its Own Is Insufficient To Support A Claim for Bad Faith Under Pennsylvania Law

Cozen O'Connor on

A low-ball settlement offer on its own is not enough to state a claim for a bad faith according to a federal district court for the Eastern District of Pennsylvania which granted the insurer’s motion to dismiss the insured’s...more

Zelle  LLP

5th Circ. Brings Consistency to Improper-Joinder Analysis

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Weather events in recent years have led to a surge of lawsuits seeking coverage for property damage. Often, in an effort to defeat diversity jurisdiction, a Texas resident will sue both a foreign insurance company and a...more

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