Case Law Update: Cannon v. Safeco Insurance — Bad Faith Insurance Claim Denial

Trever Cannon v. Safeco Insurance Company of Illinois

Court: Court of Appeals of Georgia
Date Filed: March 16, 2026
Docket Number: A25A1847

Background

Policyholder Trever Cannon filed a property damage claim with Safeco Insurance Company of Illinois, a Liberty Mutual subsidiary that writes homeowners policies across multiple states including Florida. After the claim was denied, Cannon brought a bad faith action against the carrier alleging improper claims handling practices.

Key Issues

The case addressed whether Safeco acted in bad faith in its handling and denial of the property damage claim. Bad faith insurance litigation examines whether a carrier failed to properly investigate, evaluate, or pay a claim — and whether its conduct fell below the standard of good faith and fair dealing owed to policyholders.

Court's Decision

The Georgia Court of Appeals examined the evidence of Safeco's claims handling practices and the basis for its denial decision. The ruling addresses the standard for proving bad faith against a property insurance carrier and the types of evidence that support or undermine such claims.

Why This Matters for Public Adjusters

While this case was decided under Georgia law, it has significant implications for Florida claims professionals because:

• Safeco (Liberty Mutual) is a major carrier writing property policies in Florida
• Bad faith standards across southeastern states inform Florida litigation strategy
• The case illustrates common carrier denial tactics that PAs should watch for
• It demonstrates the importance of documenting every step of the claims process for potential bad faith referrals

Practical Takeaway: When Safeco or any carrier denies a legitimate property claim, document every communication, every delay, and every justification they provide. This documentation becomes critical evidence if the claim is later referred to an attorney for bad faith litigation under Florida Statute 624.155.

Read the Full Opinion on CourtListener →

Practical Advice for Similar Cases

If you suspect carrier bad faith:

• Document every carrier interaction. Keep a detailed log of all communications with dates, times, and what was promised.
• Track statutory deadlines. Under F.S. 627.70131, carriers must acknowledge claims within 14 days and pay or deny within 90 days.
• Send follow-up letters after phone calls to create a paper trail the carrier cannot deny.
• Refer to an attorney before the claim closes. Bad faith claims under F.S. 624.155 require a Civil Remedy Notice with specific procedural steps.
• Never accept a lowball offer without review. Document the gap between the carrier offer and your estimate.

Need help with a similar claim? Submit your policy for a free review by our property damage attorneys, or call us at 833-657-4812.