"Red Flags" Provide "Ample Basis For Denial" Of Theft Claim

The Western District of Pennsylvania recently granted an insurer's motion for summary judgment to dismiss a bad faith claim after finding that the insurer did not act in bad faith by investigating "red flags." See Howell v. Progressive Ins. Co., No. 2:19-cv-1111 (W.D. Pa. May. 11, 2021).

In Howell, the insured reported her vehicle had been stolen, and the insurer opened a claim for the reported theft. The insured reported that prior to the theft she had stopped at a grocery store to shop for her grandmother with the intent of subsequently delivering the groceries to her. The insured reported that she left her key fob in the car when she went into the grocery store. A parking lot surveillance video showed that an individual peered into two other vehicles before entering and driving away with the insured's vehicle.