Safeco Insurance Co. of Illinois v. Locklair
Safeco sought a declaration that it timely tendered its $10,000 bodily injury limit within 90 days of actual notice of the claim under the 2023 bad-faith amendments, § 624.155(4)(a), Fla. Stat. The court held that issuing a check and placing it with a commercial carrier addressed to claimant's counsel constituted a 'tender' regardless of whether counsel actually received the package, and that enclosing a 'proposed form release' open to modification did not render the tender impermissibly conditional. Summary judgment was granted for the insurer.
Key facts
- Safeco Insurance sought a declaration that it timely tendered its $10,000 bodily injury policy limit within 90 days of actual notice of a claim under Florida's 2023 bad-faith amendments.
- Safeco issued a check for the full policy limit and placed it with UPS for delivery to claimant's counsel within thirty days of notice, along with a proposed form release marked open to modification.
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Why it matters
This is one of the first written decisions construing the 90-day policy-limits safe harbor added by the 2023 bad-faith amendments, § 624.155(4)(a), Fla. Stat. It supplies defense counsel with authority that mailing or… — full analysis with a trial
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