Supreme Court
In re State Farm Mut. Auto. Ins. Co.
- Case number: 23-0755
- Legal category: Insurance
- Subtype: Insurance Code Liability
- Set for oral argument: October 3, 2024
Case Summary
The issue in this case is whether the trial court must sever and abate Insurance Code claims when a motorist sues her insurance company for underinsured motorist benefits and violations of the Insurance Code.
Mara Lindsey alleges that she was injured in an automobile accident. Lindsey settled with the driver of the other vehicle for his insurance policy limit and then sought underinsured motorist benefits from State Farm. State Farm, through its claims adjuster, offered Lindsey far less than she claims she is entitled to under her policy. Lindsey sued State Farm and the claims adjuster, seeking a declaratory judgment that she is entitled to additional benefits and for violations of the Insurance Code. State Farm moved to sever and abate the Insurance
Code claims until the underlying declaratory judgment action determines the amount of liability and damages caused by the allegedly underinsured motorist. Lindsey opposed the motion, arguing that bifurcation is the proper procedure for underinsured motorist cases, and discovery on the extracontractual claims is permitted against the insurer before the bifurcated trial. The trial court denied State Farm’s motion and the court of appeals denied mandamus relief.
State Farm petitioned for a writ of mandamus from the Supreme Court. State Farm argues that the Insurance Code claims should have been severed and abated and that Lindsey is not entitled to discovery on those claims until she establishes that she is entitled to underinsured motorist benefits because the liability and damages caused by the underinsured driver exceeded the amount of the third party’s policy limits. State Farm also argues that because the claims should have been abated, the trial court abused its discretion in refusing to quash the depositions of State Farm’s corporate representative and claims adjuster, who lack personal knowledge about the facts of the underlying accident. Finally, State Farm argues that the trial court abused its discretion by limiting State Farm’s access to Lindsey’s medical records when her medical condition is at issue. The Court granted argument on the petition for writ of mandamus.
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