News & Analysis as of

Uninsured and Under-Insured Motorists Bad Faith

Carlton Fields

Seventh Circuit Affirms Judgment Dismissing Bad Faith Claim Without Viable Breach of Contract Claim

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In Wolf v. Riverport Insurance Co., the Seventh Circuit Court of Appeals affirmed the dismissal of an insured’s bad faith settlement delay claim against her insurer after she attempted to recover under section 155 of the...more

Cozen O'Connor

Texas Supreme Court Reaffirms Procedure for Litigating Bad Faith Claims in UM/UIM Cases

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In In Re State Farm Automobile Insurance Co. and Lindsey Nicole Dessart, 712 S.W.3d 53 (Tex. 2025), the Texas Supreme Court clarified the proper procedure for litigating bad faith claims related to uninsured/underinsured...more

Rivkin Radler LLP

New York Insurance Coverage Law Update — Compilation 2024

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An owner, general contractor (GC) and subcontractor (Sub) were sued by injured workers at a construction site, and they were defended by the Sub’s insurer, U.S. Specialty Insurance Company. U.S. Specialty tendered their...more

Marshall Dennehey

A Claim for Bad Faith Must Be Plausible, Not Just Possible

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Hampton v. Progressive Insurance Company, Slip Copy, 2024 WL 2301366 - Robert Hampton purchased up to $15,000 in underinsured motorist coverage from Progressive for losses incurred in 2023. Steven Vicioso caused his car to...more

Sands Anderson PC

Virginia’s New Bad Faith Law: What Insurers Need to Know

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On July 1, 2024, new Virginia Code § 8.01-66.1 became effective and created a new bad faith cause of action that can be significant for underinsured or uninsured (“UIM”) carriers....more

Sheppard Mullin Richter & Hampton LLP

New Insurance Law: The Extension of California’s “Genuine Dispute” Doctrine to Disputes Over the Value of General Damages In...

One of the most powerful weapons an insurance company can use to defeat a bad faith claim is the “genuine dispute” doctrine. Under this doctrine, as long as there was a genuine dispute regarding coverage or the amount owed,...more

Butler Weihmuller Katz Craig LLP

Attorney’s Fees as an Element Damages in an Uninsured Motorist Bad Faith Lawsuit Make the Plaintiff Whole, not His or Her...

A plaintiff cannot recover attorney’s fees in a Florida lawsuit for Uninsured Motorist (“UM”) benefits unless there is a dispute about whether the insurance policy provides coverage.  However, attorney’s fees from the...more

Cozen O'Connor

Colorado: No Bad Faith Claim Against Claims Adjuster

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On March 14, 2022, the Colorado Supreme Court held that a bad faith cause of action does not accrue against an insurance company’s adjuster employee. This important decision affirms that Colorado’s claims adjusters cannot be...more

Kennedys

Newly signed bill opens the door for bad faith suits against auto insurers providing UM and UIM benefits

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On January 19, 2022, New Jersey’s Governor, Phil Murphy, passed S.B. 1559 into law, referred to as the New Jersey Insurance Fair Conduct Act (“IFCA”). The IFCA creates a private cause of action for injured motorists to sue...more

Troutman Pepper Locke

Effective Immediately: New Jersey Enacts an Insurance Bad Faith Statute for Auto Insurers

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New Jersey has enacted an insurance bad faith statute that will penalize insurers for certain types of conduct in handling claims for uninsured and underinsured motorist coverage as the result of auto accidents. The new law...more

Sheppard Mullin Richter & Hampton LLP

Insurer Entitled to Arbitrate Disputed UIM Claim Before Insured Could Pursue Bad Faith Action

Brett McIsaac v. Foremost Insurance Company Grand Rapids, Michigan, A160389 (Sonoma County Super. Ct. No. SCV-265433) (Filed 4/30/21; certified for publication 5/19/21) - McIsaac had an auto insurance policy with Foremost...more

Carlton Fields

Minnesota Supreme Court’s First Opinion on the State’s Bad Faith Statute

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The Minnesota Supreme Court in the matter of Alison Joel Peterson v. Western National Mutual Insurance Company, 946 N.W.2d 903 (Minn. 2020) opined for the first time on the state’s bad faith statute (Minn. Stat. § 604.18) and...more

White and Williams LLP

Despite No Privity of Contract, Indiana Appellate Court Holds Additional Insured with UIM Claim May Sue for Bad Faith

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Your friend invites you out to dinner. She offers to pick you up since your house is on the way. As you head toward the restaurant, your friend’s car is sideswiped by a driver who blew through a red light. You are seriously...more

White and Williams LLP

Washington Supreme Court: Adjusters Can’t Be Sued for Bad Faith

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Earlier today the Washington Supreme Court issued its highly-anticipated decision in Keodalah v. Allstate Insurance Company. The coverage community was anxiously waiting to learn if an employee claims adjuster could be sued...more

Haight Brown & Bonesteel LLP

Regional Claim Supervisor Qualifies as “Managing Agent,” Supporting Award of Punitive Damages

In Mazik v. GEICO General Ins. Co. (No. B281372, filed 5/17/19), a California appeals court upheld a judgment and award of punitive damages for bad faith delay of an underinsured motorist claim, on the ground that a claim...more

Cozen O'Connor

Quite The Split: Louisiana Third Circuit Court of Appeal Applies Ten-Year Prescriptive Period to Contract-Based Bad Faith Claims

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In a surprising decision on rehearing, on February 4, 2019, a panel of the Louisiana Third Circuit Court of Appeal reversed itself and held that bad faith claims arising out an insurance contract are subject to a ten-year...more

Haight Brown & Bonesteel LLP

Genuine Dispute Over Workers' Compensation Reduction From Uninsured Motorist Benefits Negates Bad Faith

In Case v. State Farm Mutual Automobile Ins. Co., Inc. (No. B281732, filed 11/21/18, ord. pub. 12/18/18), a California appeals court held that the allowable reduction from uninsured motorist (UM) benefits for “payable”...more

White and Williams LLP

Insureds Suing Individual Adjusters – What Will Change If The Washington Supreme Court Decides That Adjusters May Be Sued For Bad...

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In Keodalah v. Allstate Insurance Company, the Washington Supreme Court is set to determine whether individual insurance adjusters (as distinguished from the insurers for which they work) may be sued for bad faith and...more

Saul Ewing LLP

Western District of Pennsylvania Denies Cross-Motions for Summary Judgment Where Disputed Facts Exist on Claims of a "Low-Ball"...

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After Melissa Parisi sustained injuries in a vehicle collision and learned that the other motorist involved in the crash carried only $15,000 in auto insurance, she submitted an underinsured motorist (UIM) claim to State...more

Saul Ewing LLP

Federal District Courts in Maryland and Pennsylvania Address Pleading Standards in Bad Faith Claims

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Poorly Drafted Bad Faith Claim Survives 12(b)(6) Motion in District of Maryland - In Barry v. Nationwide Mut. Ins. Co., 2018 WL 724068 (D. Md. 2018), husband and wife Plaintiffs sued their uninsured motorist (“UIM”)...more

Butler Weihmuller Katz Craig LLP

Butler Wins Dismissal of a First-Party Bad-Faith Claim Involving a Civil Remedy Notice That Listed a Different Household Policy

In Florida, an insured cannot bring a first-party bad faith claim based on a claim for UM coverage unless the insured first files a Civil Remedy Notice (CRN) with the Florida Department of Financial Services. In Mathurin v....more

Saul Ewing LLP

Western District of Washington Looks to When Claim for Coverage Was First Denied in Dismissing Bad Faith Claim As Untimely

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Plaintiff Mary Coppinger was injured in 2010 when her vehicle was rear-ended by Daniel Klein. Both Ms. Coppinger and Mr. Klein were insured through Defendant Allstate. Mr. Klein had a $50,000 policy limit; Ms. Coppinger had...more

Jaburg Wilk

An Arizona Insurer Owes No Duty to Pay the "Undisputed Amount" of a UM or UIM Claim

Jaburg Wilk on

Although the Arizona Court of Appeals resolved this issue 20 years ago, I frequently see insureds' counsel argue that an insurer must pay the "undisputed amount" of a UM or UIM claim—and I just saw this argument last week—so...more

Saul Ewing LLP

Who’s Acting In Bad Faith Now? Federal Court Slams Policyholder’s Counsel on Fee Petition

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Plaintiff Bernie Clemens was injured in a motor vehicle accident in August 2009. Clemens’ attorney helped him recover $25,000 in a supplementary underinsured motorist (SUM) claim, and then sued Clemens’ insurer under...more

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