PROGRESSIVE EXPRESS INSURANCE COMPANY
v.
OLIVIA ONEY
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An insurer's decision to pursue a settlement strategy with selected claimants in a multi-claim accident case is reasonable if evaluated under the totality of the circumstances standard, and the reasonableness of such a strategy is a question for the jury.
[1] An insurer's settlement strategy involving selected claimants in a multi-claim accident case is evaluated for reasonableness under a totality of the circumstances standar…
[2] In determining whether an insurer has acted in bad faith in handling claims, the focus is on the insurer's actions in fulfilling its obligations to the insured, not on th…
Previewing 2 of 2 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“It is generally held that where multiple claims arise out of one accident, the liability insurer has the right to enter reasonable settlements[.] . . . [T]he policy [is] encouraging compromises and speedy settlements[.]”
Harmon v. State Farm Mut. Auto. Ins. Co., 232 So. 2d 206, 207-08 (Fla. 2d DCA 1970)
Progressive Express Insurance Company appealed a circuit court decision in a case involving the handling of multiple claims arising from a single acci…
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Third District Court of Appeal State of Florida
Opinion filed May 28, 2025. Not final until disposition of timely filed motion for rehearing.
________________
No. 3D24-1618 Lower Tribunal No. 21-13391-CA-01 ________________
Progressive Express Insurance Company, Appellant,
vs.
Olivia Oney, Appellee.
An Appeal from the Circuit Court for Miami-Dade County, Tanya Brinkley, Judge.
Young, Bill, Boles, Palmer, Duke & Thompson, P.A., Max Tsoy, Richard A. Weldy, and Adam A. Duke, for appellant.
The Haggard Law Firm, P.A., and James C. Blecke, for appellee.
Before FERNANDEZ, GORDO and LOBREE, JJ.
PER CURIAM.
2 Affirmed. See Harmon v. State Farm Mut. Auto. Ins. Co., 232 So. 2d 206, 207-08 (Fla. 2d DCA 1970) (“It is generally held that where multiple claims arise out of one accident, the liability insurer has the right to enter reasonable settlements[.] . . . [T]he policy [is] encouraging compromises and speedy settlements[.]” (Emphasis added)); Aldana v. Progressive Am. Ins. Co., 828 Fed. Appx. 663, 671 (11th Cir. 2020) (“Moreover, by the end of April 2014, more than four months after the collision, Progressive's pursuit of a global settlement had gone nowhere. . . . Progressive . . . failed to act with ‘any haste in attempting to get this matter resolved[.]’”); Farinas v. Fla. Farm Bureau Gen. Ins. Co., 850 So. 2d 555, 561 (Fla. 4th DCA 2003) (“[The insurer] could have elected to follow a strategy of settlement with selected claimants, if that policy were reasonable. The reasonableness of that policy is also a question for the jury[.]”); Moultrop v. GEICO Gen. Ins. Co., 304 So. 3d 1, 7 (Fla. 4th DCA 2020) (“[T]he question of whether an insurer has acted in bad faith in handling claims against the insured is determined under the ‘totality of the circumstances standard.’”); Harvey v. GEICO Gen. Ins. Co., 259 So. 3d 1, 7 (Fla. 2018) (“[T]he focus in a bad faith case is not on the actions of the claimant but rather on those of the insurer in fulfilling its obligations to the insured.” (quoting Harvey v. GEICO Gen. Ins. Co., 259 So. 3d 1,7 (Fla. 2018))).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Harvey v. GEICO Gen. Ins. Co., 259 So. 3d 1 (Fla. 2018)
- Farinas v. Fla. Farm Bureau Gen. Ins. Co., 850 So. 2d 555 (Fla. 4th DCA 2003)
- Harmon v. State Farm Mut. Auto. Ins. Co., 232 So. 2d 206 (Fla. 2d DCA 1970)