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The 10th Circuit U.S. Court of Appeals recently affirmed the ruling of the lower court and held that an insurer can recover an underlying settlement that it made on behalf of its insured as fraud damages, effectively avoiding a bad faith claim. The case is Evanston Ins. Co. v. Aminokit Labs., Inc.  No. 19-1065, 2020 U.S. Ap. LEXIS 8571 (10th Cir. Mar. 18, 2020)

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