McCoy v. Safeway Insurance Company, 1:24-cv-00071

Plaintiff Kathryn McCoy obtained a six-month auto insurance policy from Safeway Insurance, effective June 5, 2023, expiring December 5, 2023.
McCoy was informed (by a broker employee) of a monthly payment grace period but was aware the policy itself expired December 5, 2023.
Safeway mailed a renewal notice in early November stating a new policy would take effect only if payment was received by the expiration date, with no grace period for renewal.
McCoy did not pay to renew her policy before it lapsed; she was involved in an accident on December 9, 2023.
After the accident, McCoy paid for a new policy beginning December 11, 2023, and her claim for the December 9 accident was denied.
McCoy sued Safeway for breach of contract, bad faith, and failure to comply with Mississippi insurance statutes; Safeway moved for summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Breach of contract	Safeway wrongfully denied her claim after paying on time; there was a grace period.	Policy expired before accident; no coverage in force at time of loss.	No breach; policy lapsed pre-accident.
Bad faith denial	Denial was unreasonable and in bad faith.	No claim owed; coverage had lapsed.	No bad faith; no valid claim owed.
Statutory violation (Miss. Code)	Safeway disregarded cancellation/nonrenewal rules.	Safeway complied; notice was mailed; policy language clear.	No violation; plaintiff failed to show statutory noncompliance.

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
Waste Mgmt. of La., LLC v. River Birch, Inc., 920 F.3d 958 (summary judgment inferences in favor of nonmovant)
TIG Ins. Co. v. Sedgewick James of Wash., 276 F.3d 754 (conclusory allegations insufficient at summary judgment)
Essinger v. Liberty Mut. Fire Ins. Co., 529 F.3d 264 (standards for punitive damages and insurer bad faith)