Rodney R. Herrig and Larry G. Bean, as Next Friend and Guardian of Kelsey Lynn Herrig and Natalie Sue Herrig…

Summary

The Wyoming Supreme Court affirmed the district court's dismissal of third-party claimants' bad faith and statutory claims against a liability insurer arising from delayed settlement of claims against the insured. The court held that the duty of good faith and fair dealing runs only from insurer to insured, not to third-party claimants, and that no implied private right of action exists under the unfair-claims-settlement-practices statute. The court also construed the unreasonable-claim-denial statute to permit third-party recovery of fees and interest only after judgment or settlement and the insurer's subsequent unreasonable refusal to pay, and found no legislative intent to allow consumer protection claims over settlement disputes.