Johnson v. State Farm Ins.

Summary

The Court affirmed dismissal of the Johnsons' claims arising from State Farm's subrogation. It held that the made whole doctrine did not apply to attorney fees and costs incurred in recovering property damage that State Farm's policy did not cover, because State Farm had not assumed that risk. The Court also declined to reach the statutory preemption issue because the conversion claim relied on the same insufficient causation allegations as the made whole claims.