In Cicon v. State Farm Mutual Automobile Insurance Company, the Court reiterated the long-standing proposition: “Pennsylvania law does not recognize a separate breach of the contractual duty of good faith and fair dealing where said claim is subsumed by a separately pled breach of contract claim.” The court then dismissed that separate claim.
Date of Decision: March 4, 2015
Cicon v. State Farm Mutual Automobile Insurance Company, Case No. 3:14-CV-2187, 2015 U.S. Dist. LEXIS 25780 (M.D. Pa. March 4, 2015) (Conaboy, J.)