Case Citator › Motorists Mutual Insurance v. Said

Motorists Mutual Insurance v. Said

Is it still good law? What later courts have actually done to this case.

Overruled
Court
Supreme Court of Ohio
Citation
63 Ohio St. 3d 690
Decided
Confirmed treatments
1
Flagged citations read
34 of 34
Citing cases (total)
34
Treatment dates
1994
Overruled
A reviewed court has overruled this case. Overruled on the intent requirement for an insurer's bad-faith refusal to pay a claim. All 34 flagged citations have been read.
More on how this was screened

In Zoppo v. Homestead Insurance, the Supreme Court of Ohio expressly overruled Motorists Mutual Insurance v. Said and held that a claim for bad faith does not require proof that the insurer intentionally refused payment. The confirmed treatment is listed below. Later courts continue to cite Said for separate rules concerning claim investigation, the insurer's duty of good faith, and punitive damages.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

34 later cases cite Motorists Mutual Insurance v. Said; 34 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Motorists Mutual Insurance v. Said?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled

  • The Ohio Supreme Court overruled Said's requirement of actual intent for insurer bad faith and restored the reasonable-justification standard.

    Zoppo v. Homestead Insurance · Supreme Court of Ohio · filed

    For the reasons that follow, we overrule Said and hold that actual intent is not an element of the tort of bad faith.
    Read the full opinion on CourtListener →

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