Georgia Justices to Take Up 'Gotcha' Holt Demands Tuesday Morning
For years, insurers have complained that some plaintiffs lawyers abuse time limited "Holt demands" to force insurers into either coughing up policy limits or face the possibility of large "bad faith" judgments.
September 10, 2018 at 07:02 PM
3 minute read
The state's plaintiffs and defense bars will be intently watching the Georgia Supreme Court Tuesday morning as the justices weigh whether personal injury lawyers have routinely manipulated the state's bad faith law to “set up” insurers with massive judgments far in excess of their policy limits.
There has been an increasing outcry from the insurance defense bar about the use of time-limited demands for an insured's policy limits, often putting insurers under pressure to capitulate or face a “bad faith” lawsuit for failing to settle within the time demands.
They became known as “Holt demands” after the 1992 case in which the Georgia Supreme Court held that, if an insurer knows its insured is liable and the damages likely exceed policy limits, the insurer can be subject to bad faith damages if it fails to settle within those limits.
The law has been tightened so that insurers have at least 30 days to respond, but defense lawyers say some plaintiffs lawyers tack on variety of stipulations or otherwise try to play “gotcha” with insurers.
In First Acceptance Insurance Company of Georgia v. Hughes, defense lawyers and several business groups supporting them think they have a good example to plead their case.
The case began with a 2008 crash in Gwinnett County when Ronald Jackson rear-ended a car driven by Julie An, causing a chain-reaction wreck involving five vehicles. Jackson died of his injuries nearly two months later.
Jackson's acceptance policy carried a $25,000 per person, $50,000 per accident limit.
Five claims were filed against Jackson's estate, including two by An and her 2-year-old daughter, Jina Hong, who was the most seriously injured, incurring more than $327,000 in medical bills.
The insurer's investigation quickly revealed Jackson was liable, and the lawyer representing An and Hong faxed the insurer, First Acceptance, demanding Jackson's insurance information “within thirty days of the date of this letter,” and a second fax that offered a global settlement for the policy limits.
The insurer didn't interpret the letters as a time-limited demand and filed them. An's lawyer rescinded the offer and filed suit in DeKalb County six weeks later.
The case went to trial in 2011 and ended with a jury award of more than $5.4 million against Jackson's estate.
DeKalb County State Court Judge Mike Jacobs tossed the case on summary judgment, but the Georgia Court of Appeals said the issue of whether First Acceptance acted in bad faith should have been left to the jury.
More than 20 lawyers have entered appearances in the Supreme Court case, which includes amicus briefs from the Georgia Chamber of Commerce, Georgia Chemical Council, Associated General Contractors of Georgia, the Homebuilders Association and the National Federation of Independent Business, among others.
“The well-intentioned, but hopelessly flawed articulation of the test for bad faith failure to settle claims, originally set forth in Holt and its progeny, cannot be permitted to continue and expand,” the amicus brief argues.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllTrying to Reason With Hurricane Season: Mediating First Party Property Insurance Claims
'I Thank You': Attorney Leverages Daily Report Article to Turn $42K Offer Into $600K Settlement
7 minute readFirst Came the SEC, Now Investors Raise Allegations Against Acadia Healthcare
4 minute readTrending Stories
- 1Sterlington Brings On Former Office Leader From Ashurst
- 2DOJ Takes on Largest NFT Scheme That Points to Larger Trend
- 3Arnold & Porter Matches Market Year-End Bonus, Requires Billable Threshold for Special Bonuses
- 4Advising 'Capital-Intensive Spaces' Fuels Corporate Practice Growth For Haynes and Boone
- 5Big Law’s Year—as Told in Commentaries
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250