Insurance Bad Faith Demand Letter - Connecticut

INSURANCE BAD FAITH DEMAND LETTER

State of Connecticut

[LAW FIRM LETTERHEAD]

PRIVILEGED AND CONFIDENTIAL
SETTLEMENT COMMUNICATION — NOT ADMISSIBLE AS EVIDENCE
PROTECTED UNDER CONN. CODE EVID. § 4-8 AND FED. R. EVID. 408

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED — ARTICLE NO. [________________________________]
AND VIA EMAIL TO: [________________________________]
AND VIA OVERNIGHT DELIVERY TO: [________________________________]

Date: [__/__/____]

[INSURANCE COMPANY FULL LEGAL NAME]
Attn: [CLAIMS DEPARTMENT / LEGAL DEPARTMENT / SENIOR CLAIMS OFFICER]
[________________________________]
[________________________________]
[________________________], [____] [________]

Attention: [________________________________], [TITLE]
Re: FORMAL BAD FAITH DEMAND — CONNECTICUT LAW — POLICY NO. [________________________________]
Insured / Policyholder: [________________________________]
Claimant: [________________________________]
Policy Number: [________________________________]
Claim Number: [________________________________]
Date of Loss: [__/__/____]
Type of Claim: ☐ First-Party Property   ☐ First-Party UM/UIM   ☐ Liability / Duty to Defend   ☐ Disability/Life   ☐ Other: [________________]
Policy Limits: $[________________] per occurrence / $[________________] aggregate
Amount of Benefits Wrongfully Withheld: $[________________]
Total Demand (including extracontractual damages): $[________________]
Response Deadline: [__/__/____] at 5:00 p.m. Eastern Time

Dear [________________________________]:

I. INTRODUCTION AND NATURE OF DEMAND

This firm represents [________________________________] (hereinafter "our client" or "the insured") in connection with the above-referenced insurance claim under the policy issued by [________________________________] (hereinafter "the Company" or "[________________]"). This letter constitutes a formal demand for payment of all wrongfully withheld policy benefits and extracontractual damages arising from [________________]'s bad faith conduct in handling our client's claim under the laws of Connecticut.

This demand is based on:

1. [________________]'s breach of the express contractual obligations of the policy
2. [________________]'s breach of the implied covenant of good faith and fair dealing inherent in every Connecticut insurance contract
3. [________________]'s violations of the Connecticut Unfair Insurance Practices Act (CUIPA), Conn. Gen. Stat. §§ 38a-815 et seq.
4. [________________]'s violations of the Connecticut Unfair Trade Practices Act (CUTPA), Conn. Gen. Stat. §§ 42-110a et seq.
5. The independent tort of bad faith, recognized under Connecticut common law

This is a time-sensitive demand. Unless [________________] tenders the full amount of $[________________] and satisfies the additional terms described herein on or before [__/__/____], this firm will immediately file suit in Connecticut Superior Court seeking all available contractual and extracontractual remedies.

II. CONNECTICUT BAD FAITH LAW — COMPREHENSIVE FRAMEWORK

A. The Implied Covenant of Good Faith and Fair Dealing

Connecticut law is clear: every insurance contract contains an implied covenant of good faith and fair dealing. Verrastro v. Middlesex Ins. Co., 207 Conn. 179, 190, 540 A.2d 693 (1988); L.F. Pace & Sons, Inc. v. Travelers Indem. Co., 9 Conn. App. 30, 46, 514 A.2d 766 (1986). This duty is imminent in the contract itself and is owed by the insurer to its insured as a matter of law.

The existence of a contract is a necessary antecedent to any claim for breach of the duty of good faith. Macomber v. Travelers Prop. & Cas. Corp., 261 Conn. 620, 638, 804 A.2d 180 (2002). The insured's right to receive benefits under the policy is the touchstone — conduct that impedes the insured from receiving those expected benefits constitutes bad faith.

B. The Connecticut Bad Faith Standard

Connecticut courts define bad faith precisely and set a high — but not insurmountable — standard:

"Bad faith in general implies both actual or constructive fraud, or a design to mislead or deceive another, or a neglect or refusal to fulfill some duty or some contractual obligation, not prompted by an honest mistake as to one's rights or duties, but by some interested or sinister motive…. Bad faith means more than mere negligence; it involves a dishonest purpose."
— De La Concha of Hartford, Inc. v. Aetna Life Ins. Co., 269 Conn. 424, 433, 849 A.2d 382 (2004), quoting Habetz v. Condon, 224 Conn. 231, 237, 618 A.2d 501 (1992).

A coverage dispute alone does not constitute bad faith; but a dishonest purpose — including misrepresentation, concealment, manipulation of the claims process, or deliberate undervaluation designed to coerce a reduced settlement — unquestionably does. [Carrier]'s conduct in this matter goes well beyond a mere coverage dispute.

An insurer may also be held liable in bad faith when it fails to defend or indemnify under the policy, subsequent to a failure to investigate. The Connecticut Supreme Court has made clear that "[i]nsurers disclaiming their duty to defend or indemnify under the policy, subsequent to a failure to investigate, risk extracontractual liability for consequential economic and noneconomic losses." [Citing Renaissance Mgmt. Co. v. Conn. Housing Finance Auth., 915 A.2d 290 (2007)].

C. Independent Bad Faith Tort — Buckman v. People Express

Connecticut recognizes an independent cause of action in tort for an insurer's violation of its common law duty of good faith. Buckman v. People Express, Inc., 205 Conn. 166, 530 A.2d 596 (1987). This common law tort claim is separate from and in addition to CUIPA/CUTPA statutory claims. A judgment creditor or insured may pursue both simultaneously.

D. CUIPA — Connecticut Unfair Insurance Practices Act

The Connecticut Unfair Insurance Practices Act (CUIPA), Conn. Gen. Stat. §§ 38a-815 et seq., prohibits specified unfair claims settlement practices when committed "with such frequency as to indicate a general business practice." Mead v. Burns, 199 Conn. 651, 509 A.2d 11 (1986); Lees v. Middlesex Ins. Co., 229 Conn. 842, 643 A.2d 1282 (1994).

Key distinction: CUIPA itself provides only for regulatory enforcement by the Insurance Commissioner. However, CUIPA violations create a private right of action through CUTPA. Mead v. Burns, 199 Conn. at 662–63. The plaintiff must allege that the insurer committed the proscribed acts with sufficient frequency to constitute a general business practice. Evidence of similar conduct in the handling of other claims is relevant and may be obtained through discovery. Hutchinson v. Farm Family Cas. Ins. Co., 273 Conn. 33 (2005) (claims file discoverable in bad faith action).

CUIPA's enumerated unfair practices under § 38a-816(6) include:

(A) Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue
(B) Failing to acknowledge and act with reasonable promptness upon communications with respect to claims arising under insurance policies
(C) Failing to adopt and implement reasonable standards for the prompt investigation of claims arising under insurance policies
(D) Refusing to pay claims without conducting a reasonable investigation based upon all available information
(E) Failing to affirm or deny coverage of claims within a reasonable time after proof of loss statements have been completed
(F) Not attempting in good faith to effectuate prompt, fair, and equitable settlements of claims in which liability has become reasonably clear
(G) Compelling insureds to institute litigation to recover amounts due under an insurance policy by offering substantially less than the amounts ultimately recovered in actions brought by such insureds
(H) Attempting to settle a claim for less than the amount to which a reasonable man would have believed he was entitled
(I) Failing to promptly provide a reasonable explanation of the basis in the insurance policy in relation to the facts or applicable law for denial of a claim or for the offer of a compromise settlement

Heyman Assocs. No. 1 v. Ins. Co. of Pa., 231 Conn. 756, 790 (1995): "The factual inquiry [under CUIPA/CUTPA] focuses, not on the nature of the loss and the terms of the insurance contract, but on the conduct of the insurer."

E. CUTPA — Connecticut Unfair Trade Practices Act

Under Conn. Gen. Stat. § 42-110b, any person suffering an "ascertainable loss" as a result of an unfair or deceptive act in trade or commerce may bring a private CUTPA action. Because [________________] is engaged in the business of insurance — a trade — its unfair claims handling practices violate CUTPA.

Critically: "conduct by an insurance company that is related to its insurance business can be found to violate CUTPA only if it also violates CUIPA." State v. Acordia, Inc., 310 Conn. 1, 27 (2013). Because the conduct described herein violates multiple subsections of CUIPA § 38a-816(6), the CUTPA claim is well-founded.

CUTPA remedies under § 42-110g:

• Actual damages (compensatory, consequential, and economic losses)
• Punitive damages upon proof of reckless indifference or intentional conduct — § 42-110g(a); Berry v. Loiseau, 223 Conn. 786, 811 (1992)
• Attorney's fees and costs — § 42-110g(d)
• Injunctive and other equitable relief

Common law punitive damages in Connecticut are limited to reasonable attorney's fees and litigation costs (not "multiple damages" in the traditional sense). Bodner v. United Servs. Auto. Assoc., 222 Conn. 480, 492 (1992). Under § 52-240b, punitive damages in CUTPA actions may be capped at twice the actual damages in certain circumstances.

CUTPA statute of limitations: Three (3) years from the date of the unfair or deceptive act. § 42-110g(f). The conduct giving rise to this CUTPA claim occurred on or after [__/__/____]; the CUTPA deadline is [__/__/____].

F. Third-Party Claimant Limitation

If our client is a third-party claimant (not the named insured), Connecticut law limits the direct assertion of CUIPA bad faith claims prior to obtaining a judgment against the tortfeasor/insured. Carford v. Empire Fire & Marine Ins. Co., 94 Conn. App. 41 (2006). However, where our client is the named insured or is asserting rights as a subrogee or judgment creditor, full CUIPA/CUTPA standing exists. [CONFIRM APPLICABLE SCENARIO AND ADJUST ACCORDINGLY.]

III. POLICY INFORMATION AND COVERAGE

A. Policy Details

B. Coverage Analysis and [CARRIER]'s Obligation

The policy provides coverage for [DESCRIBE COVERED LOSS TYPE, e.g., "bodily injury and property damage arising from covered occurrences," "fire and extended perils on the insured dwelling," "uninsured and underinsured motorist benefits"]. The loss at issue — [DESCRIBE THE LOSS] — clearly falls within the policy's insuring agreement.

[DESCRIBE HOW CARRIER ACKNOWLEDGED COVERAGE OR WHY COVERAGE IS CLEAR]

Having [☐ acknowledged coverage / ☐ issued partial payment / ☐ accepted the defense without reservation], [________________] owes our client the following duties under Connecticut law:

☐ To conduct a thorough, fair, and objective investigation
☐ To evaluate the claim in good faith on its merits
☐ To promptly pay all amounts that are reasonably clear
☐ To communicate honestly, transparently, and promptly with the insured
☐ To refrain from using the insured's financial distress as leverage to coerce a low settlement
☐ To defend vigorously against covered claims (if a duty-to-defend policy)
☐ To attempt in good faith to settle covered third-party claims within policy limits
☐ To timely inform the insured of any coverage position, reservation of rights, or declination

[________________] has failed each of these duties, as detailed below.

IV. FACTUAL BACKGROUND AND CLAIM HISTORY

A. The Underlying Loss / Occurrence

On [__/__/____], [DESCRIBE THE UNDERLYING LOSS EVENT IN DETAIL — the facts that triggered the insurance claim, including dates, locations, persons involved, and the nature of the claim].

[ADDITIONAL FACTUAL NARRATIVE — include medical treatment, property damage, litigation background, or other relevant facts]

B. Chronological Timeline of [CARRIER]'s Bad Faith Conduct

The following timeline documents [________________]'s pattern of unfair, deceptive, and bad faith conduct:

V. SPECIFIC BAD FAITH CONDUCT — DETAILED ANALYSIS

A. Unreasonable and Unexplained Delay

[________________] has unreasonably delayed investigation, determination of coverage, and payment of this claim without justification:

• On [__/__/____], our client reported the loss. [DESCRIBE WHAT HAPPENED — or failed to happen — in the weeks following]
• As of the date of this letter, [____] days have elapsed since the date of loss, and [________________] has [☐ not paid any amount / ☐ paid only $[________________], which is grossly inadequate]
• [DESCRIBE SPECIFIC DELAYS, UNRETURNED CALLS, MISSED DEADLINES]

This conduct violates § 38a-816(6)(B) (failure to acknowledge and act promptly) and § 38a-816(6)(F) (failure to effectuate prompt, fair settlement when liability is clear).

B. Deficient and Biased Investigation

Rather than conducting the thorough and objective investigation required under Connecticut law, [________________] [DESCRIBE THE SPECIFIC FAILURES]:

• [INVESTIGATION FAILURE 1 — e.g., "Failed to retain a qualified structural engineer, instead relying on a desk review of photographs to deny structural damage claims"]
• [INVESTIGATION FAILURE 2 — e.g., "Selectively interviewed witnesses who supported the Company's preferred outcome while ignoring witnesses who corroborated the insured's account"]
• [INVESTIGATION FAILURE 3 — e.g., "Prematurely closed the investigation after [____] days without reviewing critical records"]
• [INVESTIGATION FAILURE 4 — e.g., "Made an SIU referral without any objective basis for suspecting fraud, using the referral as a delay tactic"]

This conduct violates § 38a-816(6)(C) (failure to implement reasonable investigation standards) and § 38a-816(6)(D) (refusing to pay without reasonable investigation).

C. Misrepresentation of Policy Terms and Coverage

[________________] misrepresented the policy's terms, coverage obligations, and/or the applicable law in the following specific ways:

• [MISREPRESENTATION 1 — e.g., "Told the insured that the policy's 'concurrent causation' exclusion barred the water damage claim when, under the actual policy terms and Connecticut law, only the specifically excluded peril is excluded, not the entire claim"]
• [MISREPRESENTATION 2 — e.g., "Represented that the policy did not cover code upgrade costs when the policy's ordinance-or-law endorsement expressly provides such coverage"]
• [MISREPRESENTATION 3 — e.g., "Informed the insured that the one-year suit limitation had expired when in fact [describe the tolling or waiver argument]"]

This conduct violates § 38a-816(6)(A) (misrepresentation of pertinent facts or policy provisions).

D. Grossly Inadequate Settlement Offers

[________________]'s settlement offers bear no reasonable relationship to the actual value of the claim:

[DESCRIBE THE METHODOLOGY BEHIND THE COMPANY'S OFFERS — e.g., "The Company based its offer on a contractor estimate that uses non-comparable pricing from outside the Connecticut market and excludes overhead and profit, producing a figure that no competent professional would endorse."]

This conduct violates § 38a-816(6)(F), § 38a-816(6)(H), and § 38a-816(6)(G) (compelling litigation by offering far less than owed).

E. Failure to Provide a Reasoned Explanation for Denial or Reduction

[________________] has [☐ denied the claim / ☐ offered substantially less than owed] without providing the reasoned, policy-based explanation required under Connecticut law:

• The denial/reduction letter dated [__/__/____] [DESCRIBE THE DEFICIENCY — e.g., "cites policy exclusion 'X' without explaining how that exclusion applies to the specific facts of this loss" / "states only that 'coverage is not afforded' without identifying the applicable policy provision or explaining the insurer's factual basis"]

This conduct violates § 38a-816(6)(I) (failure to provide a reasonable explanation for denial or inadequate offer).

F. Failure to Defend / Failure to Settle Within Limits (If Applicable)

☐ Failure to defend: [________________] has wrongfully refused to defend its insured in [DESCRIBE LITIGATION], citing [DESCRIBE IMPROPER BASIS]. Under Connecticut law, the duty to defend is broader than the duty to indemnify; if any count in the underlying complaint is potentially covered, the insurer must defend the entire action. [Cite relevant CT case].

☐ Failure to settle within limits: The underlying claimant, [________________________________], made a time-limited demand of $[________________] — within the policy's limits of $[________________] — on [__/__/____]. [________________] [failed to respond / rejected the demand without reasonable investigation / offered $[________________]]. As a direct result, a judgment of $[________________] has been entered / is anticipated against our client. Under Connecticut law, an insurer that fails to settle within limits when a reasonable opportunity exists is liable for the full amount of any excess judgment. General Acc. Group v. Gagliardi, 593 F. Supp. 1080 (D. Conn. 1984), aff'd, 767 F.2d 907 (2d Cir. 1984); see also Conn. Gen. Stat. § 38a-816; Zamary v. Allstate Ins. Co., 22 Conn. L. Rptr. 317 (1998).

VI. STATUTORY ANALYSIS — CUIPA/CUTPA CHECKLIST

The following CUIPA violations under § 38a-816(6) are supported by the factual record:

Evidence of General Business Practice: To establish a CUIPA claim, our client must demonstrate that [________________] engaged in the above conduct with sufficient frequency to constitute a general business practice. We have [☐ identified / ☐ are investigating] the following additional instances of similar conduct by [________________]:

• [DESCRIBE OTHER KNOWN CLAIMS, COMPLAINTS, REGULATORY ACTIONS, OR SIMILAR INCIDENTS INVOLVING THIS CARRIER — e.g., "A review of the Connecticut Insurance Department complaint database reflects [____] consumer complaints against [Carrier] for similar claim handling conduct in the last [____] years"; or "In [Case Name], filed in [Judicial District] Superior Court, [Carrier] was alleged to have engaged in the same type of investigation delay and low-ball valuation"]
• [DESCRIBE ADDITIONAL INSTANCES]

Upon commencement of litigation, our client will seek broad discovery of [________________]'s claims handling practices, reserve procedures, and quality assurance materials across similar claims.

VII. DAMAGES

A. Contract Damages — Policy Benefits Wrongfully Withheld

B. Extracontractual and Consequential Damages

Under Connecticut law, an insurer's bad faith may result in consequential damages that flow directly from the insurer's wrongful conduct — not just the policy proceeds themselves:

C. Emotional Distress Damages

Connecticut recognizes damages for emotional distress in connection with bad faith insurance claims where the insurer's conduct is directed at a covered individual and the distress is reasonably foreseeable:

[DESCRIBE OUR CLIENT'S EMOTIONAL DISTRESS — e.g., "The Company's repeated delays, misrepresentations, and coercive conduct have caused our client severe anxiety, loss of sleep, disruption of family relationships, and the ongoing stress of displacement from the family home for more than [____] months while [________________] stone-walled a legitimate claim."]

Emotional distress damages are conservatively estimated at $[________________].

D. Punitive Damages

Common Law Punitive Damages (Bad Faith Tort): Under Berry v. Loiseau, 223 Conn. 786, 811 (1992), punitive damages are available upon proof that the defendant acted with reckless indifference to the rights of others or engaged in an intentional and wanton violation of those rights. Common law punitive damages in Connecticut are limited to reasonable attorney's fees and non-taxable costs incurred in the action. Bodner v. United Servs. Auto. Assoc., 222 Conn. 480, 492 (1992).

CUTPA Punitive Damages (§ 42-110g): CUTPA authorizes a separate punitive damages award. Under Conn. Gen. Stat. § 52-240b, punitive damages in CUTPA actions may be awarded in an amount up to double the compensatory damages found by the trier of fact.

[________________]'s conduct — [HIGHLIGHT THE MOST EGREGIOUS MISCONDUCT] — reflects the reckless indifference required to trigger punitive damages under both standards.

E. Attorney's Fees — § 42-110g(d)

CUTPA expressly provides for recovery of reasonable attorney's fees and costs by a prevailing plaintiff. Given the complexity of this matter and the volume of work required, attorney's fees to date are estimated at $[________________], with substantial additional fees anticipated through trial.

F. Damages Summary

VIII. FORMAL DEMAND

A. Monetary Demand

We hereby demand that [________________] pay the total sum of $[________________] within [____] days of this letter, on or before [__/__/____], allocated as follows:

Punitive damages are not compromised by this settlement demand and will be pursued in their entirety in litigation.

B. Non-Monetary Demands

In addition to the monetary payment above, we demand that [________________]:

☐ Provide a written confirmation that the policy remains in full force with no adverse change based on this claim
☐ Produce a complete certified copy of the claim file, including all reserve history, adjuster diaries, internal communications, expert reports, and SIU materials
☐ Identify all consultants, experts, and vendors engaged in connection with this claim
☐ Correct any adverse information reported to Verisk/ISO ClaimSearch or any other industry claims database as a result of this claim
☐ Issue a written retraction of any misrepresentation made to our client regarding coverage or policy terms
☐ [________________________________]

IX. TIME-LIMITED NATURE OF THIS DEMAND

THIS DEMAND EXPIRES AT 5:00 P.M. EASTERN TIME ON [__/__/____].

This demand is made for settlement purposes only and does not constitute a waiver of any right, claim, or remedy available to our client under Connecticut law, the policy, or otherwise.

Consequences of Non-Response or Inadequate Response

If [________________] fails to accept this demand in full by the stated deadline:

1. Suit will be filed immediately in the Connecticut Superior Court, [JUDICIAL DISTRICT], asserting:
   - Breach of contract (all wrongfully withheld policy benefits)
   - Breach of the implied covenant of good faith and fair dealing
   - Independent bad faith tort under Buckman v. People Express
   - CUIPA/CUTPA violations under §§ 38a-815, 38a-816(6), 42-110b, and 42-110g
   - All consequential, emotional distress, and punitive damages available under Connecticut law
   - Attorney's fees and costs under § 42-110g(d)

2. A formal complaint will be filed with the Connecticut Insurance Department (CID), documenting all CUIPA violations:

Connecticut Insurance Department
Attn: Consumer Affairs Division
P.O. Box 816
Hartford, CT 06142-0816
Telephone: (860) 297-3800
Online: www.ct.gov/cid/consumeraffairs

3. The CID complaint will request that the Department investigate [________________] for pattern bad faith conduct and consider appropriate regulatory action, including fines, license action, and cease-and-desist orders.

4. This demand will be withdrawn and the full scope of damages — without any compromise — will be sought in litigation.

X. DOCUMENT PRESERVATION AND SPOLIATION WARNING

This letter constitutes a formal litigation hold notice. [________________________________] is required to immediately preserve and refrain from destroying, modifying, or deleting any and all documents and electronically stored information (ESI) relating to this claim and our client's insurance relationship with [________________], including without limitation:

Claim File Materials:

• All versions of the claim file (including drafts, notes, and deleted emails)
• Adjuster diaries, activity logs, and reserve history with all reserve changes and supervisory approvals
• All communications with the insured, claimant, counsel, or public adjuster
• All photographs, videos, drone footage, and inspection reports
• All expert, consultant, engineering, or appraisal reports obtained by or on behalf of [________________]

Internal Policies and Procedures:

• Claim handling manuals, desk guidelines, and written procedures applicable to this type of claim
• Training materials and bulletins relating to the investigation and evaluation of [CLAIM TYPE] claims
• Any circular, memorandum, or guidance issued regarding changes to claims handling protocols

Financial and Reserve Information:

• Reserves set on this claim, with dates of changes and supervisory approvals
• Claims budgets and any loss cost containment targets applicable to this claim

Oversight and Quality Assurance:

• All quality assurance, supervisory review, peer review, or audit reports touching this claim
• Any compliance or ethics committee review materials
• Litigation management guidelines applicable to this claim

Failure to preserve this evidence will result in a spoliation motion, request for adverse inference instructions, and sanctions. See Conn. Practice Book § 13-14.

XI. CONCLUSION

[________________] issued our client a policy of insurance and collected premiums in exchange for a binding promise to handle claims fairly and in good faith. That promise has been broken. The conduct described in this letter — [BRIEFLY SUMMARIZE: e.g., "more than [____] months of delay, a sham investigation, a denial unsupported by the facts or the policy, and a settlement offer less than one-quarter of the actual loss"] — is not an honest mistake. It is bad faith.

Connecticut law provides our client with robust remedies precisely because the legislature and courts understand the devastating impact that insurer bad faith has on individuals and families who rely on their policies in times of crisis.

We urge [________________] to take this demand seriously, engage in a good faith evaluation of the merits, and resolve this claim before the cost of bad faith litigation — in attorney's fees, punitive damages, and reputational harm — far exceeds the cost of simply doing right by your insured.

We remain available to discuss this matter prior to the deadline.

Respectfully submitted,

[LAW FIRM NAME]

By: ___________________________________
[ATTORNEY NAME]
Juris No. [____________________]
[________________________________]
[________________________], CT [________]
Telephone: ([____]) [____]-[________]
Facsimile: ([____]) [____]-[________]
Email: [________________________________]

Counsel for [________________________________]

ENCLOSURES:
☐ Policy declarations page and applicable endorsements
☐ Correspondence chronology with [________________]
☐ Independent estimate / appraisal
☐ Expert reports
☐ Photographs and damage documentation
☐ Medical records and bills (if applicable)
☐ Claim file materials obtained to date
☐ Evidence of comparable claims / other CUIPA violations (under seal / redacted as appropriate)
☐ [________________________________]

CC:

• [________________________________] (Client)
• Connecticut Insurance Department (if complaint filed simultaneously)
• File

CONNECTICUT BAD FAITH — QUICK REFERENCE

SOURCES AND REFERENCES

• Conn. Gen. Stat. § 38a-816(6) (CUIPA — enumerated unfair practices): https://www.cga.ct.gov/2021/pub/chap_704.htm
• Conn. Gen. Stat. § 38a-815 (CUIPA — definitions): https://www.cga.ct.gov/2021/pub/chap_704.htm
• Conn. Gen. Stat. § 42-110b et seq. (CUTPA): https://www.cga.ct.gov/current/pub/chap_735a.htm
• Mead v. Burns, 199 Conn. 651, 509 A.2d 11 (1986)
• Lees v. Middlesex Ins. Co., 229 Conn. 842, 643 A.2d 1282 (1994)
• Buckman v. People Express, Inc., 205 Conn. 166, 530 A.2d 596 (1987)
• Verrastro v. Middlesex Ins. Co., 207 Conn. 179, 540 A.2d 693 (1988)
• De La Concha of Hartford, Inc. v. Aetna Life Ins. Co., 269 Conn. 424, 849 A.2d 382 (2004)
• Heyman Assocs. No. 1 v. Ins. Co. of Pa., 231 Conn. 756, 653 A.2d 122 (1995)
• Berry v. Loiseau, 223 Conn. 786, 614 A.2d 414 (1992)
• Bodner v. United Servs. Auto. Assoc., 222 Conn. 480, 610 A.2d 1212 (1992)
• State v. Acordia, Inc., 310 Conn. 1, 73 A.3d 711 (2013)
• Hutchinson v. Farm Family Cas. Ins. Co., 273 Conn. 33, 867 A.2d 1 (2005)
• Carford v. Empire Fire & Marine Ins. Co., 94 Conn. App. 41, 891 A.2d 55 (2006)
• General Acc. Group v. Gagliardi, 593 F. Supp. 1080 (D. Conn. 1984)
• NAIC Private Rights of Action Chart (CT entries): https://content.naic.org/sites/default/files/model-law-chart-mc-55-private-rights-of-action-for-unfair-claims-settlement-practices.pdf
• ALFA International Connecticut Insurance Law Compendium: https://www.alfainternational.com/compendium/insurance-law/connecticut/
• Connecticut Insurance Department Consumer Affairs: https://www.ct.gov/cid
• Cozen O'Connor — Connecticut Bad Faith (2013): https://www.cozen.com/news-resources/publications/2013/no-bad-faith-recovery-based-on-insurer-s-investigation-of-claims-under-connecticut-law