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After Reaching a Settlement of multiple claims presented against her insurer that was also the insurer of the third party, Connie Humes sued for bad faith and violation of the Unfair Trade Practices Act (UTPA). Humes appealed trial rulings by the trial court, excluding evidence of certain settlement amounts paid by Farmers Insurance Group, in a trial of her injury claims. In Connie Humes v. Farmers Insurance Exchange and Mid-Century Insurance Company, 2022 MT 148, No. DA 21-0422, Supreme Court of Montana (July 26, 2022) the Montana Supreme Court resolved the dispute. THE ISSUE BEFORE THE MONTANA SUPREME COURT Did the District Court abuse its discretion by excluding evidence of settlement amounts paid in a global settlement of multiple claims by Farmers Insurance Group in a subsequent trial of claims under the UTPA? FACTUAL BACKGROUND Barney Benkelman rear-ended Humes\' vehicle at a stoplight in Helena, causing injury to Humes. Benkelman was covered by Farmers Insurance Exchange (FIE) for bodily injury liability. Humes was insured by Mid-Century Insurance Company (Mid-Century), including underinsured motorist coverage (UIM) with a $250,000 limit, and medical payment coverage (med-pay) with a $50,000 limit.
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