A federal judge has tossed out a bad-faith case over underinsured motorist coverage against State Farm, calling it a re-packaged version of the same issues that had already been resolved.

In Ridolfi v. State Farm, U.S. Magistrate Judge Martin C. Carlson of the Middle District of Pennsylvania granted State Farm's motion to dismiss Tracey Ridolfi's common law bad-faith claims against the insurance company, finding she had already been unsuccessful in bringing statutory bad-faith claims.

“The renewal of this bad-faith claim in the guise of a contractual bad-faith claim in our view runs afoul of the law of the case doctrine in this case where we have already rejected a factually identical statutory bad-faith claim,” Carlson said in his opinion issued Oct. 5.

Ridolfi's car was hit by an underinsured motorist in 2008. According to Carlson's opinion, she opted to settle the case with the underinsured driver's insurance company for $85,000, less than her $100,000 policy limit.

She sued State Farm in 2013 for the $50,000 to $100,000 policy limit. Carlson said her policy limit was actually $100,000 to $300,000, and State Farm offered $200,000. However, Ridolfi and her husband then demanded $700,000.

“We are provided with no new evidence which would compel a different result here. Instead, the evidence seems to continue to show that State Farm gave the Ridolfis greater insurance coverage than they requested at a reduced premium rate, but briefly misstated the scope of that coverage, describing the coverage as that initially sought by Ridolfi and not as the higher level of coverage actually provided by this insurer,” Carlson said.

“When this discrepancy was brought to its attention, State Farm promptly reformed its policy to provide the Ridolfis with that greater level of coverage and potential recovery,” he continued.

Carlson concluded, “As a factual matter there is simply nothing about the fact that State Farm provided greater coverage to Ridolfi than that requested, or paid for, by the plaintiff which would permit an inference of bad faith.”

And while the plaintiff complained of delays in the claims process, Carlson said she was not entirely without fault.

“Once this claim was made by Ridolfi's counsel, the parties engaged in an on-going process aimed at attempting to resolve this claim. These efforts were unsuccessful but that lack of success, standing alone, does not demonstrate bad faith,” Carlson said. “Quite the contrary, even when we construe the evidence in a light most favorable to the plaintiff, we find that this claims processing chronology reflects a confluence of events and actions, and that in some instances the plaintiff's own actions contributed to some of these delays.”

Ridolfi's lawyer, Steven R. Snyder of Harrisburg, and State Farm's lawyer, Claire B. Neiger of Goldberg, Miller & Rubin in Philadelphia, did not respond to requests for comment.

P.J. D'Annunzio can be contacted at ­215-557-2315 or [email protected]. Follow him on Twitter @PJDannunzioTLI.