Rosen-Wohl v. State Farm Fire And Cas. Co

(Homeowner Policy's One-Year Limitations Clause Barred Insured's UCL Action Effectively Seeking Policy Benefits, Even Though a Four-Year Limitations Period Ordinarily Applies To UCL Claims and the Insurer Briefly Reopened the Previously Denied Claim Within the One-Year Period in Response To Insured's Inquiry)

(September 2023) - In Rosen-Wohl v. State Farm Fire and Cas. Co., 93 Cal.App.5th 436 (July 1, 2023), California's First District Court of Appeal affirmed the trial court's order sustaining State Farm's demurrer in an unfair competition law (UCL) action arising out of State Farm's denial of homeowner benefits, based on the policy's one-year contractual limitations period.