Doyle v. Pekin Insurance Company, 2:22-cv-00638

Plaintiff Taylor Doyle suffered injuries in a car accident and alleged her damages exceeded the at-fault driver’s insurance coverage, triggering a claim for underinsured motorist (UIM) benefits.
Doyle had a multi-vehicle insurance policy with Pekin Insurance Company providing UIM coverage on two vehicles, but Pekin paid only one vehicle’s policy limit without allowing stacking of UIM coverages.
Several class actions were filed in Arizona after Heaton v. Metropolitan Group recognized that, in the absence of notice, Arizona law demands stacking UM/UIM coverages under A.R.S. § 20-259.01(H).
Doyle filed this putative class action for breach of contract and bad faith, paralleling the same legal theory as related cases, and quickly moved for certification of a settlement class after the Arizona Supreme Court confirmed the stacking rule in Franklin v. CSAA General Ins. Co.
The parties reached a class-wide settlement for $12.45 million and presented it for preliminary approval, encompassing 94 affected policyholders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Should the settlement class be certified under Rule 23?	Class meets numerosity, commonality, typicality, and adequacy.	No opposition; class criteria are met.	Class certification granted for settlement purposes.
Does the settlement meet preliminary approval standards?	Negotiated at arm’s length, provides fair, adequate relief.	No opposition; settlement fair and reasonable.	Settlement preliminarily approved.
Is class action superior to individual actions?	Efficiency, judicial economy, and small individual damages.	No opposition.	Class action is superior to individual adjudication.
Are the claims typical and common to all class members?	All claims arise from similar contracts and denied stacking rights.	No opposition; form contracts used and uniform practices.	Typicality and commonality satisfied.

Heaton v. Metropolitan Group Property & Casualty Insurance Co., 502 P.3d 528 (Ariz. Ct. App. 2021) (Arizona law requires stacking of UM/UIM coverage unless insurer provides appropriate notice)
Franklin v. CSAA General Insurance Co., 532 P.3d 1145 (Ariz. 2023) (multi-vehicle policies must allow stacking of UM/UIM coverages unless notice is given)
Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (2011) (standards for class certification under Rule 23)
Hanlon v. Chrysler Corp., 150 F.3d 1011 (9th Cir. 1998) (criteria for class action settlements and adequacy of relief)
Churchill Village, L.L.C. v. General Electric, 361 F.3d 566 (9th Cir. 2004) (factors for evaluating class action settlements)