Adrian Fridman v. Safeco Insurance Company of Illinois

The conflict issue in this case is whether an insured is entitled to a determination of liability and the full extent of his or her damages by first bringing an’ uninsured/underinsured motorist (UM) action before litigating a first-party bad faith cause of action under section 624.155, Florida Statutes (2007). The related issues we address are whether that determination of damages is then binding, as an element of damages, in a subsequent first-party bad faith cause of action against the same insurer,' and whether the trial court in this case erred in retaining jurisdiction to allow the…