Allstate Insurance Co. v. Ray, as personal representative of the Estate of Deborah L. Veilleux
In a bad faith action against Allstate arising from a $21.8 million excess judgment, the trial court compelled production of employee personnel files and documents on Allstate's claims-department business goals and metrics. The Second District granted certiorari in part, quashing the order to the extent it required immediate production of personnel files and materials over which attorney-client privilege or work product was asserted without a prior in-camera review.
Key facts
- Allstate Insurance Co. appealed a trial court order compelling production of employee personnel files and documents regarding claims-department business goals and metrics in a bad faith action arising from a $21.8 million excess judgment against the insurer.
- The trial court ordered immediate production of nonparty employees' personnel files and privileged materials without conducting an in-camera review to segregate relevant from irrelevant material or addressing asserted attorney-client privilege and work product objections.
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Why it matters
Useful ammunition for insurers and employers resisting sweeping personnel-file discovery in bad faith litigation: the opinion confirms that redaction alone is not a substitute for in-camera review where requests sweep… — full analysis with a trial
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