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A Philadelphia federal judge entered summary judgment in favor of Allstate Insurance Co. in a bad faith claim by an underinsured motorist policyholder, holding that delay in handling a claim — without more — does not mean that the carrier has acted in bad faith.

Eastern District Judge Marvin Katz said in a 22-page memorandum opinion released Tuesday that the passage of time alone does not show bad faith, and that courts must look at the context of the impasse between a claimant and an insurance carrier before deciding that there has been a bad faith denial of coverage.

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