May 2018 Bar Bulletin
By McKean J. Evans
On March 26, the Court of Appeals (Division One) issued an important, published ruling upholding claims against an individual insurance adjuster for bad faith and violations of the Consumer Protection Act. In Keodalah v. Allstate Insurance Company and Tracey Smith,1 the court ruled the bad faith and CPA claims could proceed against the Allstate adjuster (Smith) in her individual capacity, stating: “[W]e hold that an individual insurance adjuster may be liable for bad faith and CPA violations.” This significant ruling has several implications for future insurance bad faith litigation.
The Trial Court Dismissed the Claims against Smith