A federal district court in Florida has affirmed that Florida law does not recognize common-law first-party bad faith claims against insurance companies.
The Case
Alison Swanson sued her insurer, State Farm Mutual Automobile Insurance Company, for an improper denial of benefits. After a mistrial was granted in the lawsuit, she filed another action against State Farm, asserting a single claim for what she described as "the willful tort of bad faith."
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