Legal Opinion

Armstrong v. Safeco Insurance

Washington Supreme Court

Decided December 15, 1988No. 54870-6PublishedCited by 13 opinions

1Opinion of the Court

Pearson, C.J. —

When an insurance company issues a notice of nonrenewal pursuant to RCW 48.18.292, does the insurer's duty of good faith mandate that the statutorily required reason for nonrenewal be based upon some increased actuarial risk to the insurer?

Safeco Insurance Company (Safeco) first insured Jack and Linda Armstrong under a contract of automobile insurance issued in 1977. The policy provided coverage for 6-month periods and remained in effect following successive renewals until November 14, 1984. The policy made the following provisions for nonrenewal:

If we decide not to renew this…

2Cases cited10 opinions

  1. Tank v. State Farm Fire and Casualty Co.Washington Supreme Court · 1986
  2. Stuart v. Coldwell Banker Commercial Group, Inc.Washington Supreme Court · 1987
  3. Tyler v. Grange Ins. Ass'nCourt of Appeals of Washington · 1970
  4. State Ex Rel. Gunning v. OdellWashington Supreme Court · 1961
  5. Coira v. Florida Medical Ass'n, Inc.District Court of Appeal of Florida · 1983

5 more not listed; retrieve them via the Exa API.

3Cited by13 opinions

  1. Wingert v. Yellow Freight Systems, Inc.Washington Supreme Court · 2002
  2. State v. SunichCourt of Appeals of Washington · 1994
  3. State v. TaplinCourt of Appeals of Washington · 1989
  4. Buell v. Security General Life InsuranceDistrict Court, D. Colorado · 1992
  5. Fraternal Order of Eagles v. GRAND AERIECourt of Appeals of Washington · 2001

8 more not listed; retrieve them via the Exa API.

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