Rosenberg-Wohl v. State Farm Fire & Casualty Co.

Summary

The court held that the one-year limitations period in the standard fire insurance policy and Insurance Code section 2071 does not bar an unfair competition claim seeking only broad declaratory and prospective injunctive relief concerning an insurer's general claims-handling practices. Because the action sought no direct or indirect recovery of policy benefits and was filed within the UCL's four-year limitations period, it was timely. The court reversed the Court of Appeal's judgment and remanded for further proceedings.