Automobile Insurance - Bad Faith Claims-Superior Court of Pennsylvania

Condio v. Erie Insurance Exchange 2006 PA Super 92 (April 25, 2006)

Holding: An insurer does not have a heightened duty of good faith to its insured in the context of a first party claim, as opposed to a third party claim, but does have a duty of good faith and fair dealing towards its insured. This duty also applies to an insurer’s handling of uninsured and underinsured motorist claims, and does not allow an insurer to protect its own interests at the expense of its insured’s interests, not does it require an insurer to sacrifice its own interests by blindly paying each and every claim submitted by an insured to avoid a bad faith lawsuit.