On February 15, 2022, the United States Court of Appeal for the Eleventh Circuit upheld the Southern District of Florida’s summary judgment victory for GEICO, finding that no reasonable jury could conclude that GEICO had operated in bad faith with respect to its handling of a wrongful death claim against its insured. Ellis v. GEICO Gen. Ins. Co., No. 21-12159, 2022 WL 454176 (11th Cir. Feb. 15, 2022). This case reinforces that under Florida law, an insurer may take a reasonable time to investigate a claim, and that, absent time to investigate or a settlement demand, an insurer need not voluntarily tender policy limits. About The Author
