Farmers Union Mutual Insurance Company, Inc. v. Randall and Heather Robertson

Summary

The court affirmed certification of a class alleging that the insurer improperly depreciated labor costs when adjusting actual-cash-value property claims. It held that the representatives' claims were typical because they arose from the same alleged conduct and legal theory as the class claims, and that common liability issues predominated even though individual damages or defenses might later require bifurcation, subclasses, or decertification. The court also held that the insurer waived review of any inadequacy in the circuit court's findings concerning a purported personal-property claim by failing to timely request specific findings.