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The Court of Appeals of Washington, Division One decided this week that all persons engaged in the business of insurance, including individual adjusters, may be liable for bad faith and violating Washington’s Consumer Protection Act, whether or not there is a contractual relationship between the parties. The case is Keodalah v. Allstate Ins. Co., No. 75731-8-I, 2018 Wash. App. LEXIS 685 (Ct. App. Mar. 26, 2018).

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