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State Farm Mutual Automobile Insurance Co. v. Fisher

Colo.May 21, 2018No. Supreme Court Case 15SC472Cited 247 times
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Case Details

Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
appeal to Colorado Supreme Court; affirmed lower court judgment

Related Laws

No specific laws identified for this ruling.

Outcome

Colorado Supreme Court affirmed that an insurer violated its statutory duty under CRS § 10-3-1115 by unreasonably delaying payment of covered underinsured motorist benefits while disputing other claim components, upholding the jury award for the insured driver.

Excerpt

Insurance—Underinsured Motorist Benefits—Unreasonable Delay/Denial of Payment. The Supreme Court held that under CRS § 10-3-1115 insurers have a duty not to unreasonably delay or deny payment of covered benefits, even though other components of an insured's claim may still be reasonably in dispute. Here, an insurer issued multiple underinsured motorist insurance policies that covered a driver who was injured by an underinsured motorist. Though the insurer agreed that its policies covered the driver's medical expenses, it refused to pay them because the insurer disputed other amounts (including lost wages) that the driver sought under the policies. A jury found that the insurer violated CRS § 10-3-1115, which provides that an insurer "shall not unreasonably delay or deny payment of a claim for benefits owed to or on behalf of any first-party [insured] claimant." Because the Court of Appeals properly upheld the driver's jury award, the Court affirmed its judgment.

What This Ruling Means

**What Happened** A driver was injured in an accident with an underinsured motorist and filed a claim with State Farm for underinsured motorist benefits under multiple policies. While State Farm agreed the policies covered the driver and that benefits were owed, the company delayed paying out the benefits for an unreasonable amount of time. State Farm argued they were still investigating and disputing other parts of the claim, which justified the delay in payment. **What the Court Decided** The Colorado Supreme Court ruled against State Farm, finding that the insurance company violated state law by unreasonably delaying payment. The court determined that even when an insurer is still investigating or disputing other aspects of a claim, they cannot use that as an excuse to delay paying benefits they know are clearly covered and owed. **Why This Matters for Workers** This ruling strengthens protections for workers who have insurance coverage through their employers or personal policies. It establishes that insurance companies cannot drag their feet on paying legitimate claims simply because they're still arguing about other parts of the case. Workers can expect faster payment of undisputed benefits, reducing financial hardship while dealing with injuries or accidents.

This summary was generated to explain the ruling in plain English and is not legal advice.

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