Progressive Select Insurance Co. v. Lloyd's of Shelton Auto Glass, LLC, as assignee of Bruce Farlow
In a windshield AOB bad faith case, the Second District reversed an order allowing Lloyd's of Shelton to amend to seek punitive damages under section 624.155(5). The court held the proffered evidence did not provide a reasonable basis to conclude Progressive's discounted NAGS-based pricing, immediate invocation of the policy appraisal provision, Safelite 'steering' communications, or selection of an appraiser with a business relationship to the insurer were willful, wanton, and malicious or in reckless disregard of the insured's rights.
Key facts
- Progressive Select Insurance Co. denied an assignment of benefits claim from Lloyd's of Shelton Auto Glass for windshield replacement services, relying on negotiated network pricing and immediately invoking the policy's appraisal provision when the claimed amount exceeded Progressive's determined rate.
- Lloyd's of Shelton, as assignee of the insured Bruce Farlow, brought a bad faith claim and moved to amend the complaint to add punitive damages under section 624.155(5), alleging Progressive engaged in willful, wanton, and malicious conduct or reckless disregard through discounted pricing, steering communications, and selection of a potentially conflicted appraiser.
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Why it matters
This is a significant win for insurers defending windshield AOB bad faith litigation and a detailed roadmap for attacking punitive damages amendments under sections 768.72 and 624.155(5). The court holds that appellate… — full analysis with a trial
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