Beck v. Farmers Insurance Exchange

Beck (plaintiff) was insured by Famers Insurance Exchange (Farmers) (defendant). Under Beck’s policy, Farmers agreed to provide Beck with reimbursement for medical expenses and uninsured motorist benefits in the event Beck was involved in an accident with an uninsured motorist. On January 16, 1982, Beck was injured in a hit-and-run accident. The owner of the car that hit Beck said that her car was stolen and denied knowledge of the incident. The car owner’s insurance company denied Beck’s claim. Beck filed claims with Farmers for medical expenses and uninsured motorist benefits. Farmers granted Beck’s claim for medical expenses but denied his claim for uninsured motorist benefits. On June 23, 1982, Beck offered to settle his claim for uninsured motorist benefits with Farmers for $20,000; the policy limit. Beck alleged that his claim was worth substantially more than $20,000. Farmers rejected Beck’s settlement offer without explanation on July 1, 1982. On August 2, 1982, Beck filed suit in Utah state court against Famers. Beck brought contract and tort law claims against Farmers, including breach of contract (contract claim), bad faith in refusing to investigate or settle Beck’s uninsured motorist claim (tort claim), and intentional infliction of emotional distress (tort claim). During the trial proceedings, Farmers offered to settle Beck’s uninsured motorist claim for $15,000. Beck accepted this offer allegedly due to financial pressures caused by the substantial expenses he incurred in the ten months since his accident due to Farmers’ delay in paying Beck for his claim. Beck submitted the affidavit of a former insurance adjuster stating that a prudent insurance company would have valued Beck’s claim at up to $40,000, and that Farmer’s delay in settling the claim constituted bad faith. Farmers provided no evidence to rebut this affidavit. The trial court granted judgment for Farmers, and Beck appealed.