Summary Judgment To Insurer: Continuing Investigation & Negotiation Implies Reasonableness

The Eastern District of Pennsylvania recently granted an insurer's motion for summary judgment and dismissed the insureds' bad faith claim after finding that the insurer's continued investigation and negotiation of the insureds' property damage claim was reasonable.  See Davis v. Safeco Ins. Co. of Illinois, 2021 WL 3603037 (E.D. Pa. Aug. 13, 2021).

In Davis, the insureds' property sustained structural water damage and damage to personal belongings when a toilet malfunctioned and overflowed.  The insurer prepared an estimate for the structural damage and paid its insured consistent with that estimate.  Additionally, when the insureds provided the insurer with a spreadsheet showing personal property damage, the insurer paid the insureds for certain personal property.  The insureds next sought reimbursement for the price of painting the home, but the parties could not agree and the insurer refused to pay the amount requested.  Negotiations subsequently deteriorated,