Reynolds v. American Hardware Mutual Insurance

SMITH, Judge Pro Tem.1

Today we are asked whether Idaho law will support a cause of action in tort against an insurer that negligently failed to make a timely settlement of an insurance claim. The question arises in the context of an appeal from a jury verdict for the plaintiff. The verdict granted the recovery to the plaintiff policy holder for damages suffered when a pending sale of items salvaged from his fire-damaged lease-hold property was lost. The jury agreed with Reynolds’ contention that the defendant’s unreasonable delay in settling his claim was the proximate cause of the loss of…