Scott Ayotte v. American Economy Insurance Company

MEMORANDUM *

The district court granted summary judgment in favor of American Economy Insurance Company (“American Economy”) on Ayotte’s claims for advance medical payments under Ridley v. Guaranty National Insurance Co., 286 Mont. 325, 951 P.2d 987 (1997) and common law bad faith. Ridley holds that under a Montana *658statute, a liability insurer may not defer payment of an injured third party’s medical expenses until final settlement, if liability is “reasonably clear,” and it is “reasonably clear that the expense is causally related to the accident in question.” Id. at 992. The district court…