Win Myint and Wife Patti K. Myint Plaintiffs/appellants v. Allstate Insurance Company, Defendant/appellee

Summary

The Tennessee Supreme Court held that the Consumer Protection Act applies to insurance companies: the Insurance Trade Practices Act, the bad faith statute, and the Consumer Protection Act are complementary legislation, and the comprehensive Title 56 insurance regulations do not foreclose a Consumer Protection Act claim against an insurer. Applying the Act to the facts, however, the Court concluded that Allstate's denial of the Myints' fire-loss claim was neither unfair nor deceptive but a reasonable reaction to suspicious circumstances, so the dismissal of the Consumer Protection Act claim was affirmed. The Court also held that the trial court's $13,106 prejudgment interest award was not a manifest and palpable abuse of discretion, clarifying that reasonable dispute over the existence or amount of an obligation does not automatically bar such an award. The Court affirmed in part and reversed in part the Court of Appeals' judgment.