Notable Third Quarter 2025 Updates In Insurance Class Actions – Q3 2025

The third quarter of 2025 was another eventful quarter for total loss valuation class actions. The U.S. Court of Appeals for the Fourth Circuit and the Ninth Circuit followed the lead of other circuits, rejecting certification of classes challenging certain adjustments utilized in total loss vehicle valuations. Soon after, however, the Sixth Circuit bucked that trend and affirmed certification of a similar class.

Elsewhere, a California federal court rejected a new total loss class action theory involving retained salvage vehicles, while the Idaho Supreme Court established the parameters for which insureds could assert claims for "illusory" underinsured motorist coverage.

In the life insurance space, insurers continue to face negative results in "cost of insurance" class actions. However, the Ninth Circuit reaffirmed that class certification was not appropriate for putative class claims involving allegedly deficient termination notices relating to life insurance