Trinity Universal Insurance v. Ohio Casualty Insurance

¶1 Trinity defended and settled a personal injury claim made against Ohio’s insured. Trinity then sued Ohio for subrogation, equitable contribution, and insurer bad faith under the CPA1 and IFCA.2 When Ohio failed to appear, Trinity obtained a default order and *191judgment for defense and indemnification costs, as well as treble damages under the CPA and IFCA. Trinity claims that under the principle of equitable subrogation, it was entitled to assert the insured’s CPA and IFCA claims against Ohio, even without express agreement. We reverse the portions of the judgment based on the CPA and IFCA…