Ryan Corbridge v. Encompass Indemnity Company

Date: 10-28-2025

Case Number: 23-cv-00262

Judge: Jolie A. Russo

Court: United States District Court for the District of Oregon (Multnomah County)

Plaintiff's Attorney:

Defendant's Attorney:

Description: Portland, Oregon, insurance lawyer represented the Plaintiff who sued on bad faith breach of contract theory.

AI Overview

Oregon bad faith insurance law has significantly evolved, particularly with the 2023 Moody v. Oregon Community Credit Union decision, which allows policyholders to sue insurers for certain unfair claims handling practices under a common law negligence claim. This allows for recovery of emotional distress and extracontractual damages that were previously unavailable. It is now possible for insureds to seek compensation beyond just the policy benefits if an insurer violates the Unfair Claims Settlement Practices Act (ORS 746.230).

Key aspects of Oregon's bad faith law

The Moody decision:
The Oregon Supreme Court's ruling opened the door for policyholders to sue for negligence when an insurer violates ORS 746.230. This allows policyholders to seek damages for emotional distress and other extra-contractual damages, which were previously not recoverable.

ORS 746.230:
This statute outlines prohibited actions by insurers, including misrepresenting policy terms, failing to act promptly on claims, attempting to settle for less than a reasonable amount, and not promptly explaining claim denials.
Elements of a claim:
To prove a bad faith claim, a policyholder must show:

A valid insurance claim exists.

The insurer delayed or denied the claim.
The insurer's grounds for delay or denial were unreasonable or unfair.
The policyholder suffered damages as a result.

Impact on future litigation:
The Moody decision is expected to lead to an increase in first-party bad faith litigation, as it provides a new avenue for policyholders to seek compensation for the impacts of unfair claims handling.

Examples of unfair claims settlement practices

Failing to acknowledge and act promptly on claim-related communications.

Misrepresenting facts or policy provisions to policyholders.
Failing to conduct a reasonable investigation of a claim.
Not attempting in good faith to settle a claim promptly once liability is reasonably clear.
Attempting to settle for an amount less than what a reasonable person would expect.

Outcome: 10/28/2025 89 ORDER issued by Magistrate Judge Jolie A. Russo: The parties shall file a formal Joint Status Report by 11/4/2025 advising as to the status of this case. If the case remains ongoing and because all prior case management deadlines have now expired, the parties shall confer and include within their report revised case management deadlines. (gm) (Entered: 10/28/2025)
10/28/2025 90 Stipulated Notice of Voluntary Dismissal . Filed by Encompass Indemnity Company. (Brannon, John) (Entered: 10/28/2025)
10/28/2025 91 ORDER issued by Magistrate Judge Jolie A. Russo: As this case is dismissed upon receipt of the parties' Stipulated Notice of Voluntary Dismissal 90 pursuant to Federal Rule of Civil Procedure 41(a)(1)(A), the 11/4/2025 deadline for filing a formal Joint Status Report is Stricken. (gm) (Entered: 10/28/2025)

Plaintiff's Experts:

Defendant's Experts:

Comments: