UNITED AUTO. INS. CO. v. Colon

990 So.2d 1246 (2008)

UNITED AUTOMOBILE INSURANCE COMPANY, Appellant,

v.

Mariela COLON, Appellee.

No. 4D07-3281.

District Court of Appeal of Florida, Fourth District.

September 24, 2008.

Lara J. Edelstein, Coral Gables, for appellant.

Lisa A. McNelis of Roselli & McNelis, P.A., Boca Raton, for appellee.

FARMER, J.

Florida common law did not recognize bad faith claims by an insured against the carrier, holding instead that the insured was limited to breach of contract damages and attorneys fees. In 1982 the Legislature amended section 624.155 to provide that bad faith damages recoverable under the…