Bad Faith Blog

Manu, a GEICO insured, filed suit against his uninsured motorist (UM) insurance carrier to recover for statutory bad faith failure to pay the UM policy limit until after the insured obtained a judgment against the uninsured tort-feasor. The insured’s bad faith claim was dismissed. The Supreme Court of Virginia affirmed the dismissal finding the insurance company owed no duty to settle the insured’s demand until the insured obtained a Judgment against the uninsured tort-feasor. Therefore, the insured had no claim subject to the covenant of good faith until the insurance carrier had a contractual liability to pay the UM claim.