MARCH 2014 BAD FAITH CASES: BAD FAITH CLAIM DISMISSED BECAUSE FILED MORE THAN TWO YEARS FROM ALLEGED ACT OF BAD FAITH (Philadelphia Federal)
In Hatchigian v. State Farm Ins. Co., the insured claim that the carrier improperly made out a settlement check to both him and his lawyer. He asserted a bad faith claim, but did not file the action for more than three years after the check was issued. As the statute of limitations on bad faith claims under 42 Pa.C.S. § 8371 is two years, the claim was dismissed.