IDC Properties, Inc. v. Chicago Title Insurance Company

Summary

The United States District Court for the District of Rhode Island grants Chicago Title Insurance Company’s motion in limine and motion for summary judgment in IDC Properties’ remaining bad-faith claim. The court excludes evidence and testimony concerning the North Unit because it was not covered under the policy and concludes that Chicago Title had a reasonable basis in law and fact for denying coverage concerning the South and West Units. The court therefore enters judgment for Chicago Title on the bad-faith claim.

Holdings

1. Evidence and testimony concerning coverage or value of the North Unit were not relevant to the remaining bad-faith claim because the North Unit was not covered by the policy and therefore could not support an underlying breach or bad-faith refusal to pay.
2. IDC waived reliance on the unsigned 1997 draft endorsement as a basis for asserting North Unit coverage.
3. Chicago Title was entitled to summary judgment on IDC's bad-faith claim because the undisputed record showed reasonable bases in law and fact for the denial and no intentional or reckless failure to investigate or evaluate the claim.

Questions Presented

1. Whether evidence, expert testimony, and lay testimony concerning coverage or value of the North Unit were relevant and admissible in the remaining bad-faith proceeding.
2. Whether IDC waived reliance on an unsigned 1997 draft endorsement as a basis for asserting North Unit coverage.
3. Whether Chicago Title was entitled to summary judgment on IDC's Rhode Island statutory bad-faith claim concerning the South and West Units.
4. Whether Chicago Title had a reasonable basis in law or fact for denying coverage and whether it intentionally or recklessly failed to investigate or evaluate IDC's claim.

Disposition

dismissed