Blanchard v. State Farm Mutual Auto Insurance Company

Donald Blanchard (plaintiff) was permanently injured when he was struck by a vehicle driven by an uninsured motorist. Blanchard had an insurance policy through State Farm Mutual Auto Insurance (State Farm) (defendant) that included coverage for damages caused by uninsured motorists. State Farm refused to pay Blanchard’s uninsured-motorist claim for the accident. Blanchard then filed a negligence claim in state court against the uninsured motorist and sought to compel State Farm to pay out under Blanchard’s uninsured-motorist policy. The trial court ruled that the uninsured motorist was negligent and ordered State Farm to pay out the full policy coverage amount. State Farm did not appeal the state court decision. Blanchard then sued State Farm in federal district court under diversity jurisdiction, arguing that, as defined by Florida law, State Farm denied his uninsured-motorist claim in bad faith. State Farm challenged, arguing that Blanchard’s bad-faith claim should have been raised in the state court action, not in a separate federal court action. The district court dismissed Blanchard’s claim. Blanchard appealed to the Eleventh Circuit. On joint motion by State Farm and Blanchard, the Eleventh Circuit certified a question to the Florida Supreme Court about whether a claim that an insurance company denied uninsured-motorist coverage in bad faith could accrue before the issuance of a formal determination regarding the insurance company’s liability to pay out under the policy.