Homeland Insurance Company of New York, Defendant Below, Appellant v. Corvel Corporation, Plaintiff Below, Appellee.

Summary

The Supreme Court of Delaware reversed summary judgment for CorVel because its Louisiana bad-faith claim accrued no later than June 23, 2011, when CorVel settled the underlying Louisiana proceedings and could plead the elements of its claim. The three-year limitations period therefore expired before CorVel filed suit in 2015. The court also held that Delaware's insurer-notice statute did not apply because the claimed bad-faith damages were distinct from damages recoverable under the insurance contract. The court did not reach Homeland's arguments concerning the alleged misrepresentation or causation.