United States Court of Appeals for the Second Circuit

In Woodhams v. Allstate Fire & Cas. Co., 2012 U.S. App. LEXIS 3 (2d Cir. N.Y. Jan. 3, 2012), the Second Circuit Court of Appeals affirmed the dismissal of a proposed class action against Allstate Fire and Casualty Company over its reimbursement practices for property damage. Specifically, the court ruled that Allstate's practices had not violated either New York law or the policy itself.

After fire damage to their home, plaintiffs Thomas D. Woodhams and Charlene Connors (the insureds) filed a claim with Allstate. Under the terms of the Allstate policy issued to the insureds, Allstate paid the insureds the actual cash value of their damaged property. The pertinent policy language stated as follows...

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