Drummond v. State Farm Mut. Auto Ins. Co.

Citations

• 206 N.E.3d 1274
• 2023 Ohio 283

Syllabus

Trial court did not err when it denied a stay of discovery on the insureds' bad faith claim against their underinsured motorist carrier and ordered production of the claims file prior to trial of the breach of contract claim, because the trial court permitted the insurer to redact attorney-client communications prior to production and the insurer failed to show that the claims file contained additional attorney-client communications. Nor did the trial court abuse its discretion when it compelled immediate production of work product materials in the claims file as the trial court provided a reasonable explanation for doing so and the prejudice to the insurer was minimal. Trial court abused its discretion, however, when it compelled production of work product materials pertaining solely to the insurer's defense of the bad faith lawsuit but not otherwise probative of the insurer's alleged bad faith in processing the claim. Judgment affirmed in part and reversed in part, and case remanded.