A Florida federal court recently ruled that third-party beneficiaries under an insurance contract were not entitled to attorney fees under Fla. Stat. § 627.428 where they were not named in the insurance contract. In Conyers et al. v. Balboa Insurance Company, 2012 U.S. Dist. LEXIS 42340 (M.D. Fla., Mar. 26, 2013) (Hernandez Covington, J.),
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Attorney Fees Not Recoverable Under Bi-Economy and Panasia According To New York’s Appellate Division, Second Department
By Guest Contributor on
Posted in Bad Faith
In 2008, the New York Court of Appeals decided the companion cases of Bi-Economy Market, Inc. v. Harleysville Ins. Co., 10 N.Y. 3d 187) (2008) and Panasia Estates, Inc. v. Hudson Insurance Co., 10 N.Y. 3d 200 (2008), which held that “consequential damages resulting from a breach of the covenant of good faith and…