Baxter v. State Farm Mut. Auto. Ins. Co.
Annotate this CaseSteve Baxter, who was insured by State Farm, was injured in a motor-vehicle accident. State Farm paid medical coverage in the amount of $5000 and informed the tortfeasor's insurer carrier, Farmers Insurance, of its notice of subrogation rights. Baxter informed State Farm that the amount of his settlement with Farmers was not sufficient for him to be made whole and filed a petition for declaratory judgment and complaint for bad faith against State Farm. Later Baxter filed an amended declaratory action to invalidate lien and complaint for injunctive relief, deceptive trade practices, bad faith, and tortious interference with a contract. The circuit court found that State Farm had a valid but unenforceable lien against any settlement paid to Baxter and dismissed count one of Baxter's complaint with prejudice. Baxter appealed, arguing the court erred in dismissing the first count of his complaint because, pursuant to the Supreme Court's case law, an insurer's right to subrogation only arises once the insured has been made whole. The Court reversed and remanded for the reasons set forth on the same day in Riley v. State Farm Mutual Automobile Insurance Co.
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