The Court of Appeals of Washington, Division One decided this week that all persons engaged in the business of insurance, including individual adjusters, may be liable for bad faith and violating Washington's Consumer Protection Act, whether or not there is a contractual relationship between the parties. The case is Keodalah v. Allstate Ins. Co., No. 75731-8-I, 2018 Wash. App. LEXIS 685 (Ct. App. Mar. 26, 2018).

 In 2007 the vehicle Moun Keodalah was driving collided with a motorcycle. After Kedoulah fully stopped at a stop sign and began to cross the street in his truck, a motorcycle ran into Kedoulah's truck at a high rate of speed, injuring Keodalah and killing the motorcyclist. The Allstate insurance policy that Kedoulah had on his vehicle included underinsured motorists coverage, and the motorcyclist carried no auto insurance.

 The Seattle Police Department did an investigation on the collision that revealed that the motorcyclist was traveling at or over 70 miles per hour, more than twice the legal limit in the 30mph speed zone. Seattle PD also investigated Keodalah's phone records and discovered that Keodalah was not using his cell phone at the time of the accident.