Reliance On Expert Opinions Demonstrates Reasonableness

The Eastern District of Pennsylvania recently granted an insurer's motion to dismiss a bad faith claim after finding that the insurer immediately conducted an investigation into the insured's claim by hiring two professionals, and reasonably relied on the professionals' opinions when denying the insured's claim. See Covenant Realty v. Westminster American Ins. Co., 2021 WL 4963519 (E.D. Pa. Oct. 26, 2021).

In Covenant Realty, the glass skylight atrium of the insured's apartment building collapsed, leaving a hole in the roof and causing debris to fall into the building's elevator vestibule. The insured immediately filed a claim with their insurer and retained a public adjuster to investigate the cause of the atrium collapse and to assist with the claims submission process. Upon notice of the claim, the insurer also retained an adjuster and a structural engineer to conduct its own investigation of the cause of the collapse. Both parties agreed that the collapse was