Panag v. Farmers Ins. Co. of Washington

Summary

The court held that the Consumer Protection Act applies to allegedly deceptive efforts to collect an unadjudicated insurance subrogation claim, even when the plaintiff has no consumer or business relationship with the defendant and the parties' underlying relationship is adversarial. The five-element CPA framework incorporates standing, and a plaintiff need not have paid the claimed amount to establish injury; investigation expenses and other costs caused by deceptive collection practices may suffice. The court affirmed the Court of Appeals and remanded the claims for further proceedings.