In This Issue:

- Court of Appeals of Michigan: Trial Court’s Incorrect Instruction on the Definition of Bad Faith Did Not Require Reversal

- District of Colorado: Insureds Have No Obligation To Hire Public Adjusters To Recover Amounts Due Under A Policy

- Eastern District of Pennsylvania: Bad Faith Claim Rejected Where Insurer Requested Examination of Claimant, Made Settlement Offer Below Policy Limits, and Paid Award One Day After Appeal Period Expired

- Excerpt from: Court of Appeals of Michigan: Trial Court’s Incorrect Instruction on the Definition of Bad Faith Did Not Require Reversal

- American Physicians Capital, Inc. (“AP Capital”) provided medical malpractice insurance coverage to emergency room physician Robert Prodinger, a member of Battle Creek Emergency Physicians, P.C. (“BCEP”). The AP Capital policy had a policy limit of $300,000. Following the death of Daniel Symons, a patient treated under Prodinger’s supervision, the Symons Estate brought a wrongful death action against Prodinger and BCEP.