News & Analysis as of

Settlement Bad Faith

Akerman LLP

Abracadabra – How a Stalking Bill Magically Turned into Revisions to a Georgia Settlement Statute

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In Georgia’s recent Legislative Session, Senate Bill 83 started off addressing the eligibility for restraining orders related to stalking, but there must have been some magic pixie dust floating around the House Committee...more

Presley & Presley

No Settlement Opportunity, No Problem

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The vast majority of extra-contractual/bad faith cases involve a carrier’s failure to secure a release of an insured by accepting a reasonable settlement opportunity within the policy limits. The absence of a reasonable...more

White and Williams LLP

New York Court Holds Insurer Can Recover Before Insured Is Made Whole

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In State Farm Fire & Cas. Co. v. Tamagawa, Index No. 510977/2021, 2023 N.Y. Misc. Lexis 5434, the Supreme Court of New York considered whether an insurance carrier can settle its property subrogation lawsuit with the...more

Adams and Reese LLP

Deeper Dive into HB 837 – Potential Effects, Challenges of Wide-Ranging Florida Tort Reform Bill

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Last month, we provided an overview of Florida Tort Reform HB 837 - a wide-ranging tort reform bill ratified on March 24, 2023. With the stated goal of stabilizing the state’s insurance market, the bill’s sweeping provisions...more

Farella Braun + Martel LLP

More Stringent California Claim Law Could Benefit Policyholders

To combat a perceived litigation tactic by plaintiffs counsel of using settlement demands within policy limits to set up insurers for bad faith, insurance company associations lobbied for statutory clarification to avoid...more

Rumberger | Kirk

Breaking it Down: What Florida Insurers Need to Know about Bad Faith After Tort Reform

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Bad-faith litigation is a hot topic in Florida following the passage of the new tort-reform measure known as House Bill 837. However, even in the face of reasonable legislative changes, it remains important for insurers and...more

King & Spalding

Southern District of Ohio Finds Bank’s Settlement of Fraudulent Transfer Claim Uninsurable

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On December 16, 2022, the U.S. District Court for the Southern District of Ohio held that a settlement of a fraudulent transfer suit was not covered under the settling defendant’s insurance policies. Huntington National Bank...more

Rumberger | Kirk

Eleventh Circuit: Disagreement Over Valuation Is Not Per Se Bad Faith

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A little more than one year after Progressive scored a bad faith win in Eres v. Progressive American Ins. Co., 998 F.3d 1273 (11th Cir. 2021), Progressive came away with another victory in Deary v. Progressive American Ins....more

Adams and Reese LLP

Bad Faith on the Bayou

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The last few years have brought unprecedented hurricane seasons in the Gulf South, with Louisiana’s coastal communities bearing much of the impact. Those storms brought property damage; that property damage brought insurance...more

Butler Weihmuller Katz Craig LLP

Good Faith: Plaintiffs’ Complaints About Release Held Invalid

The United States Court of Appeals for the Eleventh Circuit recently addressed the issue of whether tendering a policy limits check on a liability policy with an overbroad release could constitute bad faith. In Pelaez v....more

Cozen O'Connor

Lack of Notice No Excuse for Failure to Settle

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An insurer can no longer claim its lack of notice of a lawsuit against its insured excuses it for failing to settle the suit after the Georgia Supreme Court’s recent decision in GEICO Indemnity Co. v. Whiteside, Case No....more

Wiley Rein LLP

Ninth Circuit Holds that Excess Carrier May Challenge Allocation of Primary Carrier’s Settlement that Resolves Both the Underlying...

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Applying California law, the Ninth Circuit held that an excess insurer may challenge the allocation of an underlying settlement that resolves both an underlying claim against an insured and the insured’s coverage dispute with...more

Butler Weihmuller Katz Craig LLP

The Many Faces Of Multiple Liability Claims: Two Divergent Opinions From The Eleventh Circuit Court Of Appeal

The Eleventh Circuit Court of Appeals recently released two opinions involving multiple liability claims against an insured with insufficient policy limits.  Both cases involved appeals from summary judgment orders in bad...more

Greenberg Glusker LLP

Ninth Circuit Court of Appeal Rules that Excess Insurer Cannot Challenge Exhaustion of Underlying Insurance on Coverage Grounds

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In Axis Reinsurance Co. v. Northrop Grumman Corporation, 2020 DJDAR 10114 (9th Cir. Sept. 14, 2020), a case of first impression under California law, the Ninth Circuit held that an excess insurer may not dispute exhaustion of...more

White and Williams LLP

How a Little-Known Senate Bill Could Help Stem the Tide of Bad Faith Litigation in Florida

On January 14, 2020, Senator Jeff Brandes (R) introduced Florida Senate Bill 1334: Financial Services (SB 1334)[1], which would add two additional requirements to Florida Statute 624.155’s civil remedy notice provision: ...more

Carlton Fields

Trial Court Denies Post-Trial Motions in Asbestos Reinsurance Saga Involving Claims That Reinsurer Failed to “Follow the Fortunes”...

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We previously posted about the yearslong reinsurance dispute between Utica Mutual Insurance Co. (the cedent) and Century Indemnity Co. (the reinsurer), involving Utica’s claims that Century breached two reinsurance...more

Carlton Fields

When Evidentiary Error Matters: Eleventh Circuit Affirms Decision to Grant Retrial

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The U.S. Court of Appeals for the Eleventh Circuit recently closed the book on litigation in which GEICO had been involved since 2010, holding that the granting of a retrial—which resulted in a GEICO victory after an initial...more

Knobbe Martens

Gust, Inc. v. Alphacap Ventures LLC

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Federal Circuit Summary - Before Wallach, Linn and Hughes. Appeal from the United States District Court for the Southern District of New York. Summary: In determining whether to award sanctions under 28 U.S.C. § 1927,...more

Carlton Fields

Dot The I’s And Cross The T’s: The Importance Of Clarity In Claim Communications And The Availability Of Punitive Damages For An...

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The Georgia Court of Appeals recently made waves in Hughes v. First Acceptance Insurance Company of Georgia, Inc., 343 Ga. App. 693 (2017). First, it aggrandized the role of a jury in determining the existence of an offer to...more

Cozen O'Connor

Is It Bad Faith to Exercise a Contractual Right?

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A recent malpractice case highlighted this issue. In Johnson v. Proselect Insurance, the doctor/insured contended that the insurer acted in bad faith by settling a claim after trial without the doctor’s consent. The doctor...more

Spilman Thomas & Battle, PLLC

Spilman Alert - Breaking Insights: Shutting Another Door on Suing Insurance Companies in West Virginia

The West Virginia Supreme Court of Appeals recently closed an avenue for bad faith claims. In this case, the insured, CMD, sued its own liability insurance company, State Auto, for not settling the claims asserted against it...more

Proskauer - Minding Your Business

A District Court’s Discretion to Sanction Is Broad, “But For” a Causal Limitation

Recently, the U.S. Supreme Court clarified in Goodyear Tire & Rubber Co. v. Haeger that even a district court’s exercise of broad discretion to impose a civil sanction for a litigant’s bad faith conduct has to be limited by a...more

Dorsey & Whitney LLP

The Supreme Court - April 18, 2017

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Coventry Health Care of Missouri, Inc. v. Nevils, No. 16-149: The Office of Personnel Management (“OPM”) is authorized under the Federal Employees Health Benefits Act of 1959 (“FEHBA”), 5 U.S.C. §8901 et seq., to contract...more

Rumberger | Kirk

Florida 4th DCA Reiterates Insurers Negligence Not Enough to Sustain Bad Faith Claim

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Directs Judgment to be Entered in Favor of Insurer - In GEICO v. Harvey, (Fla. 4th DCA Jan. 4, 2017), Florida’s Fourth District Court of Appeal held that the trial court erred in denying the insurer’s motion for directed...more

Cozen O'Connor

Whose Settlement Is It, Anyway? Negotiating Consistent with an Insurer's Strong Coverage Defenses.

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This author suggested, in an earlier May 2016 Bad Faith blog article, that an insurer can measure on a “strength scale” its insurance coverage defenses while it defends its insured against underlying claims and lawsuits under...more

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