In re State Farm Mutual Automobile Insurance Co. (Opinion)Annotate this Case
In these original proceedings arising from suits by holders of underinsured motorist (UIM) insurance seeking recovery against their insurers following traffic accidents the Supreme Court held that insureds who bring only Insurance Code claims seeking policy benefits as damages must also succeed in an initial "car crash" trial in order to lay the predicate for their statutory claims.
Following traffic accidents, holders of UIM insurance sought recovery against their insurers. The insureds, however, did not sue for breach of their insurance companies and brought only extracontractual Insurance Code Claims. In both cases, State Farm filed motions for bifurcated trial under Rule 174(b). After the trial courts denied State Farm's motions, State Farm petitioned for mandamus relief. In response, Petitioners argued that because they brought only statutory claims and because there were no breach of contract claims to try first, no bifurcation of trial was required. The Supreme Court granted mandamus relief, holding that although Petitioners' claims were not labeled breach of contract Petitioners nevertheless just establish State Farm's liability under their insurance policies as a prerequisite to recovery on their Insurance Code claims.