Florida Multiple-Claimant Bad-Faith Claims: Summary Judgment Appropriate Where Insurer Pursues Global Settlement, Keeps Insured Informed, and Claimant Refuses to Negotiate

This appeal arose from a multi-vehicle crash caused by State Farm’s insured, Larry Stanaland, involving multiple injured claimants. The State Farm policy provided $25,000 per person and $50,000 per accident in bodily injury liability coverage. While several claimants ultimately resolved their claims through a global settlement process, Sienna Grimes did not; she pursued litigation, obtained an excess verdict (i.e., beyond policy limits), and then sued State Farm for bad faith to recover the excess amount.

The key issues on appeal were whether genuine disputes of material fact existed on State Farm’s alleged bad faith in handling competing claims, whether the district court misapplied Florida bad-faith authorities in multiple-claimant settings, and whether the court improperly weighed evidence (including expert opinions) at summary judgment.

The Eleventh Circuit affirmed summary judgment for State Farm. Applying Florida law, the court held that the record did not permit a reasonable jury to find that State Farm acted in bad faith or that any alleged shortcomings caused the excess judgment.

The court emphasized that State Farm:

• Promptly advised its insureds about liability and the risk of an excess judgment;
• Pursued a global settlement conference to address competing claims;
• Made settlement decisions in consultation with the insureds and counsel;
• Reasonably resolved three other claims within limits; and
• Faced a claimant (Grimes) who maintained an inflexible policy-limits position and declined to participate meaningfully in the global process.

The panel also upheld the district court’s refusal to treat Grimes’s expert as creating a triable issue where the opinions were deemed conclusory.

The opinion is anchored in Florida’s foundational third-party bad-faith framework and the Eleventh Circuit’s recent treatment of multiple-claimant settlement dynamics.

1) Martinez v. GEICO Cas. Ins. Co., 152 F. 4th 1323 (11th Cir. 2025)

The court cited Martinez for both the de novo standard of review on summary judgment and—more importantly—the proposition that multiple-claimant bad-faith cases can be resolved on summary judgment where the evidence is insufficient for a reasonable jury to find bad faith. The panel used Martinez to rebut the argument that multiple-claimant situations are categorically “jury-only” cases.

The panel echoed Martinez’s reasoning that an insurer’s global settlement efforts designed to “minimize the magnitude of possible excess judgments” can reflect good-faith claims handling rather than bad faith.

2) Boston Old Colony Ins. Co. v. Gutierrez, 386 So. 2d 783 (Fla. 1980)

Boston Old Colony Ins. Co. v. Gutierrez supplied the classic articulation of an insurer’s duty: the insurer must act with “the same degree of care and diligence as a person of ordinary care and prudence should exercise in the management of his own business.” The decision’s specific duties—advising of settlement opportunities, warning of excess exposure, investigating, and settling when a prudent person would—served as the measuring stick for State Farm’s conduct.

3) Novoa v. GEICO Indem. Co., 542 F. App'x 794 (11th Cir. 2013)

The panel cited Novoa for the principle that insurers must not act “solely on the basis of their own interests in settlement.” This framed the inquiry as one focused on alignment (or misalignment) between the insurer’s conduct and the insured’s protection against excess exposure.

4) Perera v. U.S. Fid. & Guar. Co., 35 So. 3d 893 (Fla. 2010)

Perera provided a decisive limiting principle: a bad-faith claim requires “a causal connection between the damages claimed and the insurer’s bad faith.” The Eleventh Circuit’s causation emphasis functioned as a gatekeeper—without evidence that State Farm’s alleged bad faith caused the excess judgment, the claim could not proceed.

5) Farinas v. Fla. Farm Bureau Gen. Ins. Co., 850 So. 2d 555 (Fla. Dist. Ct. App. 2003)

Grimes relied on Farinas to argue that State Farm’s handling of multiple claimants created a jury question. The Eleventh Circuit distinguished it. In Farinas, summary judgment was deemed improper where there was evidence the insurer settled quickly with some claimants, did not diligently pursue a global settlement, and thereby left the insured exposed in a way that “could have been minimized by wiser settlement practice.”

Here, by contrast, the panel agreed with the district court that State Farm did the very things Farinas suggests are prudent: it pursued a global settlement conference, communicated with insureds about excess risk, and coordinated settlement strategy with counsel.

6) Mesa v. Clarendon Nat'l Ins. Co., 799 F.3d 1353 (11th Cir. 2015)

Mesa reinforced that in a multiple-claimant accident, an insurer may settle with some claimants—even exhausting limits and leaving others uncompensated— so long as the approach is reasonable and consistent with good faith. The panel used Mesa to validate the legitimacy of global settlement efforts and to underscore that depletion of limits is not, by itself, bad faith.

7) Aldana Progressive Am. Ins. Co., 828 F. App'x 663 (11th Cir. 2020)

Grimes also invoked Aldana to argue that multiple-claimant cases often present triable issues. The panel again distinguished the factual showing: Aldana involved evidence the insurer did not work diligently to ensure a global settlement and failed to advise the insured about excess judgment risk and avoidance steps. In this case, the record reflected the opposite (diligent pursuit, repeated advisories, and consultation).

8) Pelaez v. Gov't Emps. Ins. Co., 13 F. 4th 1243 (11th Cir. 2021)

The panel relied on Pelaez to justify considering claimant/claimant’s-counsel conduct as part of the “totality of the circumstances.” While insurer conduct remains the focus, Pelaez supports that a claimant’s refusal to cooperate in settlement can demonstrate that the failure to settle did not stem from insurer bad faith.

9) Evers v. Gen. Motors Corp., 770 F. 2d 984 (11th Cir. 1985)

The court cited Evers for an evidentiary point crucial to summary judgment: a party cannot avoid summary judgment with an expert affidavit that is merely conclusory or unsupported. The panel applied this to discount Grimes’s expert opinions as reiterations of argument rather than evidence of specific bad-faith failures.

The Eleventh Circuit’s reasoning proceeded in three main steps:

1. Define the governing duties under Florida law. Using Boston Old Colony Ins. Co. v. Gutierrez, the court framed State Farm’s obligations as communication (settlement opportunities, excess risk, avoidance steps), investigation and evaluation, and reasonable settlement conduct, all while avoiding self-interested claims handling (Novoa).
2. Apply the “multiple claimants” overlay. Citing Farinas and Mesa, the court treated the case as one requiring an insurer to act prudently amid competing demands, including by seeking a global settlement and by making reasonable allocation decisions—even if some claims consume most limits and leave residual exposure.
3. Resolve whether a jury question existed. The court held no reasonable jury could find bad faith given the undisputed record: State Farm’s repeated communications to the insureds, its retention of counsel, its pursuit of a global settlement conference, and the insureds’ involvement and endorsement of the settlement approach. The court also considered (per Pelaez) that Grimes maintained a firm “policy-limits-only” posture and declined to engage in the global process. Finally, the court rejected attempts to manufacture a factual dispute through conclusory expert opinion (Evers).

Underlying this was the causation requirement from Perera v. U.S. Fid. & Guar. Co.: even if one could critique aspects of State Farm’s evaluation (e.g., the omission of future medical bills), the record did not support a triable showing that such issues caused the excess judgment, particularly where the insurer pursued a global strategy and the claimant refused to negotiate below the per-person limit.

Although “NOT FOR PUBLICATION,” the decision is still meaningful as a signal of how the Eleventh Circuit is operationalizing Florida bad-faith standards in multi-claimant scenarios. Its practical impacts include:

• Reinforcing summary judgment as a viable endpoint in multiple-claimant bad-faith litigation where the insurer can document global settlement efforts, insured consultation, and consistent warnings regarding excess exposure (aligning with Martinez and Mesa).
• Elevating documentation and insured involvement as protective factors: letters to insureds, explicit excess-exposure warnings, and decisions made with counsel and insured input were central to defeating the bad-faith narrative.
• Emphasizing claimant conduct as context rather than “blame shifting”: the panel confirmed that claimant rigidity can be relevant to whether the insurer’s conduct, in totality, was the reason settlement failed (Pelaez).
• Constraining expert-driven disputes at summary judgment: conclusory opinions that re-argue the case do not create genuine issues of material fact (Evers), especially in claims-handling disputes where the record evidence (communications, timelines, offers) is concrete.

For insurers, the case encourages a disciplined “global-first” strategy in pile-up accidents, paired with continuous insured advisories. For claimants pursuing bad-faith recovery, it underscores that proving bad faith requires more than pointing to an adverse outcome; plaintiffs must marshal evidence of both unreasonable conduct and causation under Perera.

• Third-party bad faith (Florida): A claim asserting the insurer mishandled settlement opportunities in a way that unreasonably exposed the insured to an excess judgment.
• Policy limits: The maximum the insurer will pay under the liability policy (here, $25,000 per person / $50,000 per accident).
• Excess judgment: The portion of a judgment above policy limits; an insured (or an assignee/claimant under certain circumstances) seeks to shift that excess to the insurer by proving bad faith.
• Global settlement conference: A process where the insurer attempts to resolve all claims from a single event together, allocating limited policy proceeds among competing claimants.
• Totality of the circumstances: Bad faith is evaluated holistically—communications, diligence, reasonableness, timing, and obstacles (including claimant posture) are all considered together.
• Summary judgment: A pretrial ruling for the moving party when no genuine dispute of material fact exists and the mover is entitled to judgment as a matter of law; courts may not weigh credibility, but may reject unsupported conclusions.
• Causation requirement: Even if mistakes occurred, a bad-faith plaintiff must show the insurer’s bad faith caused the excess judgment (Perera v. U.S. Fid. & Guar. Co.).

Sienna Grimes v. State Farm Mutual Automobile Insurance Company affirms that Florida multiple-claimant bad-faith claims can be resolved on summary judgment where the insurer’s record demonstrates diligent global settlement efforts, thorough insured communication and consultation, and a lack of evidence that any alleged claims-handling flaw caused the excess judgment. The decision also underscores that claimant refusal to negotiate may be considered in the totality-of-circumstances analysis, and that conclusory expert opinions do not create triable factual disputes.