Lockwood v. Geico General Insurance Company
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Jennifer Lockwood was injured in a car accident caused by an uninsured
drunk driver. Lockwood had car insurance through Geico General Insurance Company. After exhausting her policy's medical payments coverage, Lockwood sought payment under her uninsured motorist coverage. Geico offered $750 to settle the uninsured motorist claim, and Lockwood declined. Geico questioned Lockwood's "high" medical bills and refused to make additional medical payments outside of a total settlement of Lockwood's uninsured motorist claim. The parties eventually settled Lockwood's uninsured motorist claim for $25,000. Lockwood brought a tort claim against Geico for alleged breach of the duty of good faith and fair dealing implied in her insurance contract, arguing that Geico unreasonably delayed payment of Lockwood's uninsured motorist claim. The superior court granted summary judgment in favor of Geico on the bad-faith tort claim and awarded attorney's fees. Upon review of the matter, the Supreme Court reversed the superior court: because there was a genuine issue of material fact regarding whether Geico lacked a reasonable basis for delaying payment on Lockwood's uninsured motorist claim. The case was remanded for further proceedings.
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