Court Strikes Bad Faith & CUTPA Counts in UIM Suit

Insurance Coverage / UIM & Bad Faith (Auto)

Court partially grants, partially denies motion to strike wide-ranging UIM / bad-faith complaint against auto insurer

The plaintiff was injured in a 2022 motor vehicle collision. The tortfeasor carried liability insurance with Allstate; the plaintiff carried automobile coverage, including underinsured motorist (UIM) benefits, with State Farm. She filed a five-count complaint against State Farm alleging: (1) UIM coverage, (2) breach of contract, (3) bad-faith breach of contract, (4) unfair claim practices under CUIPA/CUTPA, and (5) intentional infliction of emotional distress (IIED). State Farm moved to strike the entire complaint. The court’s memorandum explains that some coverage and contract-based theories were legally sufficient at the pleading stage, while the bad faith, CUTPA/CUIPA and IIED were not.  The court emphasized that bad faith requires more than ordinary breach or negligence: it implies a “dishonest purpose or sinister motive” and cannot be stated merely by re-labeling the contract breach as “bad faith.” The court held plaintiff did not allege facts showing dishonest or malicious conduct—only conclusory statements that State Farm “failed to investigate in a timely manner” or “did not attempt in good faith to effectuate a prompt, fair and equitable settlement.” Those bare conclusions were not enough. To sustain a CUIPA/CUTPA claim, a plaintiff must allege more than a single, ordinary claim dispute; there must be allegations of a “general business practice” of unfair or deceptive claim handling. The complaint here alleged only mishandling of the plaintiff’s individual claim. For IIED, the plaintiff did not allege any facts showing conduct so atrocious as to be “utterly intolerable in a civilized community,” nor did she allege severe emotional distress with supporting factual detail. The court noted that an insurer’s failure to pay or properly investigate, by itself, is not the kind of extreme conduct that meets the IIED standard. Reyes-Martinez v. State Farm Mut. Auto. Ins. Co., No. DBD-CV-25-6053789-S (Conn. Super. Ct. Nov. 6, 2025).