Bad Faith

Recent News:

Legal 500 Recognizes Six Cozen O’Connor Practice Areas and 16 Attorneys in its 2023 Guide

Cozen O'Connor's Aviation (Litigation/Regulation), Construction, L&E, M&A (Midmarket), Shipping (Finance and Litigation/Regulation) practices were ranked by the Legal 500.

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Extracontractual claims pose a unique set of risks to insurers, implicating their business operations and opening potentially vast exposures. Today, it is not enough to have good coverage counsel. Insurers need counsel with deep and specific bad faith and extracontractual experience. Cozen O’Connor’s team of dedicated extracontractual/bad faith attorneys have been practicing in this field for decades.

Our bad faith attorneys defend insurance clients in litigation alleging first- or third-party extracontractual claims related to all lines of business, including property, general liability, professional liability and D&O, life/health/disability and automobile policies. We handle litigation arising from claims handling, underwriting, excess verdicts, uninsured or under-insured motorist coverage, consent judgments, default judgments and garnishment actions. Our attorneys have successfully defeated individual and class claims seeking actual and consequential damages, statutory penalties, punitive damages, attorneys’ fees and policy benefits.

Because Cozen O’Connor is a global leader in the area of insurance coverage and claims litigation, we are often able to defeat breach of contract assertions at the outset, thereby mitigating any extracontractual claims. When appropriate, our attorneys are able to negotiate quick and quiet resolutions to bad faith claims. Because they involve questions of honor, duty and essential fairness, these cases are qualitatively different from other coverage disputes. Our lawyers are able to create practical frameworks for discussion, incentivize reasonable conduct and mutuality, and find solutions that limit insurer exposure.  

When bad faith and extracontractual disputes must be tried, our attorneys have the proven ability to go to court—and win. We regularly and successfully defend major insurers in multi-million dollar bad faith matters in state, federal and appellate courts throughout the United States. Success is not defined simply by getting a defense verdict, but by winning in a way that protects clients’ bottom lines and brands.

 

SERVICE AREAS

  • Successfully defend bad faith litigation from inception through trial
  • Design strategies to defeat institutional bad faith cases
  • Respond to policy limit and time limit demands and analyze potential exposures
  • Assist in the withdrawal of a defense while avoiding bad faith, waiver and estoppel claims
  • Respond to unreasonable discovery requests and consent judgments
  • Bifurcate bad faith claims for discovery and trial, when necessary
  • Avoid or limit impact of policyholder’s assignment of rights
  • Negotiate settlements in bad faith cases with multiple insureds/claimants, multiple insurers, limited insurance; avoid or defend against collusive settlements
  • Monitor underlying litigation and assess impact on coverage issues and potential exposure
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Experience

Publications

Hurricane Coverage Ruling Clarifies Appraisal Scope In Fla.

November 20, 2024

Tiffany Bustamante, co-chair of the firm’s Bad Faith group, wrote the expert analysis column “Hurricane Coverage Ruling Clarifies Appraisal Scope In Fla.” for Law360.

Claims Notes: November 2024 [Alert]

November 11, 2024

John Ewell reviews recent cases and regulations impacting the insurance industry.

The Fine Line Between Delay and Bad Faith: Insights from the Fifth Circuit. [Avoiding Insurance Bad Faith Blog]

October 23, 2024

A prompt response is critical when disaster strikes, but as the Fifth Circuit recently ruled, delays may be excusable in certain circumstances. In First United Pentecostal Church v. Church Mut. Ins. Co., No. 23-30779, 2024 WL 4511240 (5th Cir. Oct. 17, 2024), First United Pentecostal Church sued...

The Time Limited Demand and Duty to Settle: Common Themes and Advising Your Insurer Client How to Avoid Bad Faith [Avoiding Insurance Bad Faith Blog]

September 19, 2024

There must be something in the water or the plaintiff’s bar just had a conference where the keynote speaker addressed strategies for putting pressure on insurers by issuing time-limited demands (“TLD”) because we have been asked by several insurer clients over the last few weeks to evaluate whether...

Does a Conditional Release Constitute Bad Faith? [Avoiding Insurance Bad Faith Blog]

August 23, 2024

In Brodowy v. Progressive Direct Ins. Co., the Ninth Circuit affirms the district court’s granting of Progressive Direct Insurance Company’s (“Progressive”) motion for summary judgment as to claims alleging bad faith and violations of Montana’s Unfair Trade Practices Act (“UTPA”), as well as a...

Ore. Insurance Litigation Is Testing The Bounds After Moody

August 08, 2024

Sarah Pozzi wrote the expert analysis column titled “Ore. Insurance Litigation Is Testing The Bounds After Moody” for Law360.

Claims Notes: August 2024 [Alert]

August 01, 2024

Cozen O'Connor’s Global Insurance Department's Claims Notes provides quick, to-the-point summaries of national insurance developments, including notable insurance decisions, legislation, trends, and regulatory guidance.

Next Steps for an Excess Insurer After an Unsuccessful Hammer Letter [Avoiding Insurance Bad Faith Blog]

July 18, 2024

Introduction Insurers are frequently asked to satisfy their duty of good faith and fair dealing by entertaining reasonable settlement offers within the combined limits of the policies. However, primary and excess insurers do not always agree whether a particular claim presents a significant...

A New Era for Extra-Contractual Damages in Oregon – What We Know and What We Are Learning Six Months Since Moody [Avoiding Insurance Bad Faith Blog]

June 27, 2024

The start of 2024 marked the end of an insurance era in Oregon. On December 29, 2023—the last Friday before the new year—the Oregon Supreme Court issued its much-anticipated decision in Moody v. Oregon Community Credit Union, et al., 371 Or 772 (2023). Before Moody, Oregon had long been a...

Claims Notes: June 2024 [Alert]

June 27, 2024

Cozen O'Connor’s Global Insurance Department's Claims Notes provides quick, to-the-point summaries of national insurance developments, including notable insurance decisions, legislation, trends, and regulatory guidance.

Texas Supreme Court Rejects Free Speech and Due Process Challenges to Public Adjuster Regulations [Alert]

June 10, 2024

Karl Schulz discusses the Texas Supreme Court's recent ruling rejecting Stonewater Roofing's claim that a Texas statute violated free speech and due process rights.

Claims Notes: May 2024 [Alert]

May 30, 2024

Cozen O'Connor’s Global Insurance Department's Claims Notes provides quick, to-the-point summaries of national insurance developments, including notable insurance decisions, legislation, trends, and regulatory guidance.

Claims Notes: April 2024

April 29, 2024

Cozen O'Connor’s Global Insurance Department's Claims Notes provides quick, to-the-point summaries of national insurance developments, including notable insurance decisions, legislation, trends, and regulatory guidance.

Claims Notes: March, 2024

March 26, 2024

Cozen O'Connor’s Global Insurance Department's Claims Notes provides quick, to-the-point summaries of national insurance developments, including notable insurance decisions, legislation, trends, and regulatory guidance.

Claims Notes

February 27, 2024

Cozen O'Connor’s Global Insurance Department's Claims Notes provides quick, to-the-point summaries of national insurance developments, including notable insurance decisions, legislation, trends, and regulatory guidance.

Cozen O'Connor Adds Insurance Attorneys In LA, Houston

October 17, 2023

Law360 covered the recent expansion to the firm’s insurance litigation practice by adding Julie E. Van Wert, David M. Berke, Jerome P. Doctors, and Rangi Perera in Los Angeles and Christopher Tramonte in Houston.

First Circuit Affirms Insurer’s Denial for Late Notice Under Claims-Made Policy [Alert]

August 16, 2023

The First Circuit rejected the insured’s argument that an insurer’s purported “actual knowledge” of a claim is sufficient to comply with the policy.

Oregon Legislature Falls Short On Passage of Statutory Bad Faith Cause of Action [Avoiding Insurance Bad Faith Blog]

June 29, 2023

In an unexpected and last minute turn of events, the Oregon legislature failed to pass a final-stage version of House Bill 3242 before its regular session adjourned on June 25, 2023 for the remainder of the year. Generally, if HB 3242 had been promulgated into law, it would have opened the door to...

Should I Stay or Should I Go? Recent Developments and Special Situations Impacting Removal in Insurance Cases

May 10, 2023

Stephen P. Pate co-authored the article, “Should I Stay or Should I Go? Recent Developments and Special Situations Impacting Removal in Insurance Cases” for the Defense Research Institute’s (DRI) May issue of For The Defense.

Eleventh Circuit: Jury Instruction About Notice to Insured of Settlement Demand Was Required (Florida) [Avoiding Insurance Bad Faith Blog]

July 20, 2022

In its recent decision, Brink v. Direct General Ins. Co., 38 F.4th 917 (11th Cir. 2022), the Eleventh Circuit ruled 2-1 that the Florida district court erred when it failed to instruct a jury that an insurer not only owed a duty to settle claims for its insured, but also owed a duty to advise its...

Top Bad Faith Cases of 2021

July 12, 2022

Michael W. Melendez and Chad A. Pasternack wrote the article “Top Bad Faith Cases of 2021” for Westlaw Today.

Under Texas Law, No Tender Means No Obligation To Defend [Avoiding Insurance Bad Faith Blog]

June 30, 2022

The United States Court of Appeals for the Fifth Circuit recently affirmed a long-standing Texas rule: the duty to defend is not implicated unless the insured complies with the policy’s notice-of-suit requirements and demands a defense. Moreno v. Sentinel Ins. Co., Ltd., 35 F.4th 965, 975-77 (5th...

Texas Supreme Court Axes Policyholder’s Attempt to Expand Insurer Tort Liability [Avoiding Insurance Bad Faith Blog]

June 28, 2022

In Elephant Insurance Co., LLC v. Kenyon, the Supreme Court of Texas reiterated the framework of an insurer’s common-law duties to insureds under Texas law.[1] In applying that framework to the facts of the case, the Court rejected an attempt to expand an insurer’s obligations under existing...

Intentional Act Without Intent to Harm May Not Be an Occurrence [Alert]

May 27, 2022

A California appellate court recently ruled that an intentional act may not be an "occurrence" even when there is no intent to cause harm.

California Court of Appeal: Insurers Not Liable Under the California Insurance Frauds Prevention Act [Avoiding Insurance Bad Faith Blog]

May 03, 2022

In its recent decision, People ex rel. Ellinger v. Magill, et al., ---Cal.Rptr.3d---, No. E076378, 2022 WL 1077988 (Cal. Ct. App., Mar. 18, 2022), the California Court of Appeal refused to extend liability under California’s Insurance Frauds Prevention Act (IFPA) to an insurer’s claims handling...

Montana: Unambiguous Exclusions Enforced Despite Lack of Table of Contents Required Under Statute [Avoiding Insurance Bad Faith Blog]

April 29, 2022

A recent Supreme Court decision, High Country Paving, Inc. v. United Fire & Cas. Co., 2022 MT 72, ¶ 1, answered in the negative a question certified by a federal district court regarding tensions inherent in Montana’s Property and Casualty Insurance Policy Simplification Act (“PSA”). The...

Eleventh Circuit (Florida):  No Bad Faith for Investigating Claim [Avoiding Insurance Bad Faith Blog]

March 01, 2022

On February 15, 2022, the United States Court of Appeal for the Eleventh Circuit upheld the Southern District of Florida’s summary judgment victory for GEICO, finding that no reasonable jury could conclude that GEICO had operated in bad faith with respect to its handling of a wrongful death claim...

New Statute May Spell Trouble for New Jersey Insurers [Avoiding Insurance Bad Faith Blog]

January 26, 2022

On January 19, 2022, New Jersey Governor Phil Murphy signed S.B. 1559, known as the “New Jersey Insurance Fair Conduct Act,” which allows motorists to sue their insurance companies over “unreasonably” late or denied coverage benefits and unfair settlement practices. The bill, passing through both...

Fifth Circuit Weighs in on Aftermath of Texas Supreme Court’s Decisions Affecting Insurers’ Pre-Appraisal Award Payments and Damages under the Texas Prompt Payment of Claims Act [Avoiding Insurance Bad Faith Blog]

August 20, 2021

Just a few short years ago, there was a bright line rule under Texas law concerning appraisal awards. If an insurer timely paid an appraisal award, that payment extinguished all of the insurer’s contractual and extracontractual liability to the insured. See, e.g., Garcia v. State Farm Lloyds, 514...

Fifth Circuit Finds Potential Coverage for Data Breach; Interprets “Publication” Broadly [Avoiding Insurance Bad Faith Blog]

July 23, 2021

Using general contract interpretation principles, the Fifth Circuit reversed summary judgment in favor of an insurer and found a duty to defend Landry’s in a data breach lawsuit. Landry’s Inc. v. The Insurance Company of the State of Pennsylvania, No. 19-20430 (July 21, 2021). Landry’s...

Iowa Supreme Court Rejects Restaurant’s Allegations of Bad Faith and Breach of Contract After Appraisal [Avoiding Insurance Bad Faith Blog]

June 08, 2021

The Iowa Supreme Court recently reversed the appellate court’s denial of an insurer’s motion for a directed verdict, finding that United Fire did not breach the insurance policy and did not commit bad faith during a property appraisal. Luigi’s, Inc. v. United Fire and Cas. Co., No. 19-1669, ---...

Lack of Notice No Excuse for Failure to Settle [Avoiding Insurance Bad Faith Blog]

May 28, 2021

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. S21Q0227 (Ga. April 19, 2021). In Whiteside, the Georgia Supreme Court held...

Can a Settlement Demand Above Policy Limits Fall within Limits? A Calif. Appellate Court Says Yes

March 29, 2021

Michael Melendez and Rebekah Shapiro discuss a recent California Appeals Court decision in Planet Bingo LLC v. Burlington Ins. Co., and what it means for liability insurers.

Texas Supreme Court Follows Through on Barbara Technologies and Ortiz With Three Important New Decisions [Alert]

April 22, 2020

Karl A. Schulz and Stephen P. Pate discuss three recent cases decided by the Texas Suprme Court that revived policyholder suits that were in limbo when Barbara Technologies and Ortiz were decided.

In The News

Four Cozen O’Connor Attorneys Named to 2024 Washington Super Lawyers List

July 31, 2024

Peter Berg and Jodi A. McDougall were named 2024 Super Lawyers; Sarah Pozzi and Karl Neumann were recognized as 2024 Washington Rising Stars.

Super Lawyers Names 15 Cozen O’Connor Attorneys to its 2024 Florida List

July 03, 2024

Eight Cozen O’Connor attorneys have been recognized as Super Lawyers, including Susan N. Eisenberg, James A. Gale, Howard S. Krooks, Samuel A. Lewis, Ellen S. Morris, Stuart R. Morris, Ralf R. Rodriguez, and Martin T. Schrier. The seven Cozen O’Connor attorneys recognized as Rising Stars are Heather Beale, Tiffany Bustamante, J. Kent Crocker, Arielle Eisenberg, Alexandra J. Schultz, Natasha Shaikh, and Paul Souferis.

Leading Lawyers Network Recognizes 19 Cozen O’Connor Lawyers as Top Illinois Practitioners

March 05, 2024

Ira Bodenstein, Jack Carriglio, Janet Davis, John Dunn, Mitch Edlund, Wendy Enerson, Gary Gassman, Tia Ghattas, Jeremy Glenn, Erin Bolan Hines, Mark Rabinowitz, Peter Roberts, Brian Shaw, Joseph Tilson, Julie Trester, Peter Valeta, Anna Wermuth, and Brian Williams were recognized as Leading Lawyers, Christina Sanfelippo was recognized as an Emerging Lawyer.

Five Cozen O’Connor Attorneys Named to 2024 Georgia Super Lawyers List

February 12, 2024

Recognized by their peers in Georgia as Super Lawyers are Kenan Loomis and Alycen Moss. Luciana Aquino, Dakota E. Knehans, and Danielle C. Le Jeune were named “Rising Stars,” a list that recognizes attorneys under the age of 40.

Cozen O’Connor Further Expands its Insurance Coverage Practice, Adding Litigators in Los Angeles and Houston

October 16, 2023

Julie E. Van Wert, David M. Berke, Jerome P. Doctors, and Rangi Perera joined in Los Angeles and Christopher Tramonte joined in Houston.

Five Cozen O’Connor Attorneys Named to 2023 Washington Super Lawyers List

July 31, 2023

The Seattle attorneys who have been recognized by their peers in include firm members Jodi McDougall, Terri Sutton, and William Walsh. Peter Berg and Sarah Pozzi were recognized as 2023 Washington Rising Stars.

Legal 500 Recognizes Six Cozen O’Connor Practice Areas and 16 Attorneys in its 2023 Guide

July 10, 2023

Cozen O'Connor's Aviation (Litigation/Regulation), Construction, L&E, M&A (Midmarket), Shipping (Finance and Litigation/Regulation) practices were ranked by the Legal 500.

Cozen O'Connor's Alissa Christopher named Volunteer of the Week by the Human Rights Initiative of North Texas

June 14, 2022

Alissa Christopher, Member of the firm's Global Insurance Department, was recognized as the Volunteer of the Week by the Human Rights Initiative (HRI) of North Texas.

Colorado Ruling Accelerates Debate On Adjuster Liability

March 22, 2022

John R. Ewell was quoted in the article “Colorado Ruling Accelerates Debate On Adjuster Liability” by Law360.

NJ Gov. Signs Bill To Allow 'Bad Faith' Insurance Suits

January 19, 2022

John R. Ewell was quoted in the article “NJ Gov. Signs Bill To Allow 'Bad Faith' Insurance Suits” by Law360.

Contacts

Alissa K. Christopher

Co-Chair, Bad Faith Group

akchristopher@cozen.com

(214) 462-3036

Tiffany Bustamante

Co-Chair, Bad Faith Group

tbustamante@cozen.com

(305) 358-6031

People

Awards

Five Cozen O’Connor Attorneys Named to 2023 Washington Super Lawyers List

July 31, 2023

The Seattle attorneys who have been recognized by their peers in include firm members Jodi McDougall, Terri Sutton, and William Walsh. Peter Berg and Sarah Pozzi were recognized as 2023 Washington Rising Stars.

Related Practice Areas

Related Blogs

Avoiding Insurance Bad Faith

Covering state and federal bad faith decisions and practices impacting insurers.

Cyber Law Monitor

Following current trends in cyber, privacy, and data security law.

Property Insurance Law Observer

Covering first-party decisions and developments.

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