Bad Faith in Pre-Suit Claims Handling

On July 5, 2011, Division 1 of the Court of Appeals of Washington held there was sufficient evidence for a jury to find that an insurer’s pre-suit claims handling constituted bad faith despite the fact that the insurer subsequently tendered policy limits after the plaintiff filed suit. Moratti v. Farmers Ins. Co. of Washington, 2011 WL 2611763 (2011).