Eastern District of Pennsylvania finds no third-party standing to bring a bad faith claim.

The court dismissed a pro se litigant’s bad faith action against an insurance company by a party based upon claims that the insurer refused to settle an action brought against its insured by the plaintiff. Citing other authority, the court held that “the duty to negotiate a settlement in good faith arises from the insurance policy and is owed to the insured, not to a third-party claimant.” The court held that the insurer’s fiduciary duties ran solely to its insureds and, because the plaintiff was a stranger to the relationship between the insurer and its insured, dismissed his bad faith complaint.

_{Case Law Alerts, 3rd Quarter, July 2016}

_{Case Law Alerts is prepared by Marshall Dennehey Warner Coleman & Goggin to provide information on recent developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. Copyright © 2016 Marshall Dennehey Warner Coleman & Goggin, all rights reserved. This article may not be reprinted without the express written permission of our firm.}