In this case, the court observed the distinction between applicable legal theories addressing conduct before and after an insurance policy is issued. The court observed that pre-sale conduct, if actionable, is subject to Pennsylvania’s Unfair Trade Practices and Consumer Protection Law, not its Bad Faith Statute.
Date of Decision: March 7, 2017
Romero v. Allstate, No. 16-4037, 2017 U.S. Dist. LEXIS 31965 (E.D. Pa. Mar. 7, 2017) (Schmehl, J.)