Supreme Court of Delaware

Joann Enrique, Plaintiff Below, Appellant v. State Farm Mutual Automobile Insurance Co., Defendant Below, Appellee

June 14, 20162016 Del. LEXIS 349

Summary

The Court affirmed summary judgment for State Farm because the record did not support a reasonable finding that State Farm lacked a reasonable basis for its UM claim valuations or acted with bad faith. Conflicting medical evidence about preexisting knee conditions, differing valuations by qualified reviewers, settlement efforts, and the absence of evidence that State Farm's reasons were pretextual defeated the claim. The Court also held that Enrique's expert could not supply meaningful support because his opinions principally addressed Delaware law rather than disputed facts. STRINE, Chief Justice, dissenting, would have held that the conflicting valuations, settlement conduct, and evidence of economic pressure created a jury question on bad faith.