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.
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