Key Points:

• Overview: Allstate filed a motion for summary judgment against Shawn Hart, arguing that his claim for property damage under his auto insurance policy was barred by a two-year limitation period.
• Background: Hart's vehicle was damaged in a collision on August 15, 2019, which also resulted in a fatality and charges against Hart for impaired driving. Allstate denied Hart's claim based on policy exclusions related to impaired driving. The dispute focused on when the limitation period began—either at the accident date or the date of the final denial of coverage.
• Legal Arguments:
  • Allstate: Asserted that the limitation period began on the accident date or when Hart received the denial letter in 2019.
  • Hart: Argued the limitation period began in 2020, after Allstate's investigation concluded, invoking the "discoverability" rule.
• Court's Analysis: The court found the limitation period began either at the accident date or when Allstate issued the denial letter, rejecting Hart's discoverability argument. The court held that the bad faith claim fell within the same limitation period.
• Decision: The court granted summary judgment in favor of Allstate, ruling Hart's claim was statute-barred and no trial was needed.

Monetary Award/Costs: Costs were awarded to Allstate, but the specific amount was not specified in the decision. No damages were awarded to Hart.