Eldredge v. State Farm Mutual Automobile Insurance Company, 2:12-cv-00900

Rachelle Eldredge sues State Farm for breach of contract, bad faith and intentional infliction of emotional distress over uninsured motorist (UM) denial after a June 7, 2011 Hawaii accident.
State Farm moved for partial summary judgment on the bad faith and IIED claims, arguing the UM claim was fairly debatable under Utah law.
HPD investigation concluded a single-vehicle moped accident with no evidence of a second vehicle; Eldredge’s husband suggested a second vehicle might have forced her off the road.
State Farm reviewed medical records and letters from two doctors supporting a moped-versus-automobile theory; Eldredge submitted additional letters from treating physicians.
State Farm retained a biomechanical reconstruction expert (Mecham); Eldredge retained Ingebretsen, who opined a passing vehicle struck Eldredge from behind.
DLL investigation funded by Eldredge concluded no credible evidence of a third-party vehicle; the UM policy requires clear and convincing evidence of a phantom vehicle.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether UM denial was fairly debatable	Eldredge argues investigation lacked diligence and evidence was not fairly evaluated.	State Farm relied on expert reports and investigation, which provided a good faith basis to deny.	Yes; the denial was fairly debatable under Utah law.
Whether State Farm breached the implied covenant of good faith and fair dealing	Bad faith due to failure to timely pay and disregard of evidence suggesting a third-party vehicle.	Adherence to a reasonable investigation with fair evaluation; no bad faith given debatable claim.	No; no breach found; claim dismissed.
Whether Eldredge’s IIED claim survives	State Farm’s denial caused emotional distress.	IIED requires more than a debatable denial; no extreme conduct shown.	No; IIED dismissed.

Jones v. Farmers Insurance Exchange, 286 P.3d 301 (Utah 2012) (implied covenant of good faith and debatable claims framework)
Beck v. Farmers Insurance Exchange, 701 P.2d 795 (Utah 1985) (starting point for fairly debatable analysis)
Saleh v. Farmers Ins. Exch., 133 P.3d 428 (Utah 2006) (fairly debatable standard for denial of benefits)
Prince v. Bear River Mut. Ins. Co., 56 P.3d 524 (Utah 2002) (expert reports generally provide a good faith basis for defense)
Callioux v. Progressive Ins. Co., 745 P.2d 838 (Utah Ct. App. 1987) (expert reports as basis for bad faith defense)