Supreme Court of Colorado

Steven Pham, as Personal Representative of the Estate of Louis Diep Pham, Deceased Kinh B. Pham, Na — Hobbs, J…

March 4, 20132013 Colo. LEXIS 179

Summary

Justice Hobbs dissented from the judgment affirming dismissal of the Pham Parties' underinsured-motorist claims. He would have held that the claims accrued only when the related Hartford coverage litigation became final in 2006, making the 2008 action timely, and that the allegations supported a bad-faith claim based on State Farm's duty to investigate and pursue the claims in good faith. The dissent also criticized the majority's approach as encouraging premature and piecemeal litigation.