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No proof of “outrageous” conduct is needed to win punitive damages in a bad faith case against an insurance company since Pennsylvania’s bad faith law allows for punitive awards based only on “reckless” behavior, a federal judge has ruled.

U.S. District Judge John R. Padova issued his nine-page opinion in Thomas v. State Farm Insurance Co. on the eve of a non-jury trial that began yesterday. In the opinion, Padova refused to dismiss the claims brought by the victims of a three-car accident who said the insurer had unreasonably delayed paying their uninsured motorist claims.

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