Coulter v. State Farm Mut. Auto. Ins. Co., 2014 U.S. Dist. LEXIS 5612 (N.D. Fla. 1/16/14)

The essence of an insurance bad faith claim is that the insurer acted in its own best interests.

The plaintiff was seriously injured due to a car accident involving an insured of State Farm. The plaintiff sued State Farm, alleging bad faith failure to settle the claim against its insured. The court noted that the essence of a insurance bad faith claim is that the insurer acted in its own best interests. The court determined that State Farm promptly investigated the accident and attempted to settle the claim in good faith. In fact, within six days of the accident, State Farm authorized payment of the policy limits. Because there was a complete absence of evidence that State Farm acted solely on the basis of its own interests as to the plaintiff’s claim, State Farm’s motion for summary judgment was granted.

Case Law Alerts, 2nd Quarter, April 2014