The Western District of Pennsylvania recently granted an
insurer's motion for summary judgment and dismissed claims
for breach of contract, bad faith, and unjust enrichment brought by
the assignee of claims from insureds and third-party claimants. The
Court found that the insurer had paid for repairs pursuant to the
auto policies it issued. The Court further held that a disagreement
over the insurer's repair estimates and the need for
supplemental estimates does not establish bad faith. See
Professional, Inc. v. Progressive Cas. Ins. Co, 2021 WL 4267497
(W.D. Pa. Sept. 20, 2021).
In Professional, the Plaintiff, an automotive repair shop,
alleged that the defendant insurer failed to reimburse Plaintiff
for the full cost of making repairs to automobiles that were
covered by insurance policies issued by the insurer, which included
repairing automobiles of customers who held a policy with the
insurer (“Insureds”) and customers who did not hold a
policy with the insurer
