Reed v. State Farm Mut. Auto. Ins. Co.

Summary

The court held that State Farm did not violate the statutory duties governing timely payment and fair handling of insurance claims because its partial tender was reasonable in light of unresolved causation and damages questions. The insurer reasonably investigated Reed's preexisting knee condition and was not required to obtain a deposition or independent medical examination before making the partial tender. Its later tender of the remaining policy limits was also timely and reasonable once additional medical evidence established causation, so the judgment awarding penalties and attorney fees was reversed and the suit dismissed with prejudice.