Hannah Williams, V Usaa Casualty Insurance Company

Court of Appeals of Washington·Decided July 20, 2026·No. 87724-1·Unpublished

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

HANNAH WILLIAMS, No. 87724-1-I

Appellant,

DIVISION ONE

v.

UNPUBLISHED OPINION

USAA CASUALTY INSURANCE COMPANY, a foreign insurer,

Respondent.

MANN, J. — Hannah Williams was seriously injured in a car accident. In addition to making claims against the driver of the vehicle she was in and the driver of the other car involved in the collision, she made a claim for secondary personal injury protection (PIP) and underinsured motorist insurance (UIM) benefits from her insurer, USAA Casualty Insurance Company (USAA). Williams ultimately sued USAA for breach of contract and later amended her complaint adding extracontractual claims, including violations of the Insurance Fair Conduct Act (IFCA), ch. 48.30.010-.015 RCW, the Consumer Protection Act (CPA), ch. 19.86 RCW, and the duty of good faith.

Williams appeals the trial court’s dismissal of her extracontractual claims on summary judgment. We affirm.

I

A

On September 22, 2019, Williams was the front passenger in a vehicle driven by Brandon Parker. Parker failed to yield the right of way at an intersection and pulled out in front of a vehicle driven by Juan Hernandez. Hernandez’s vehicle T-boned the front passenger side of Parker’s vehicle, gravely injuring Williams, who suffered multiple skull fractures. Williams was airlifted by helicopter to Harborview Medical Center (Harborview).

Parker was insured under a USAA policy issued to his parents. Williams opened a liability claim and a PIP claim under the Parkers’ policy.

Williams was also insured under a USAA policy issued to her parents, Erin and Mark Williams. The Williamses’ policy had medical coverage limits of $10,000 per person for PIP and $100,000 per person for UIM benefits. On October 2, 2019, at the request of Williams’s father, USAA opened two claims under the Williamses’ policy: a secondary PIP claim and a UIM claim. Both claims appear to have been opened under the same number: 2346267-022. USAA assigned adjuster Steven Kennedy to Williams’s UIM claim.

Kennedy reached out to Williams to discuss her injuries and treatment status.

Williams told Kennedy that she would follow up with a specialist to determine what additional treatment was necessary. Kennedy also contacted the liability adjuster under the Parkers’ policy, who informed him that the Parkers’ liability limits appeared to be adequate to fully compensate Williams for her accident-related injuries and treatment thus far, but did not tell him what the liability limits were. Kennedy entered a file note

indicating that he would follow up every 30 days to inquire about whether Williams had received any additional treatment.

On October 4, 2019, USAA received Williams’s medical records from Harborview. On October 11, 2019, Williams’s attorney notified USAA that she was being represented by counsel and that she would be seeking available PIP and/or UIM benefits under her parents’ policy. On October 17, 2019, USAA started making payments to Williams’s medical providers under the secondary PIP claim.

On October 31, 2019, Kennedy again confirmed with the liability adjuster that the limits appeared to be adequate. Nonetheless, the liability adjuster again did not tell Kennedy what the liability limits were. In addition, Kennedy did not know at that time if Williams was still being treated. He believed that letters were sent out requesting an update on the status of her treatment, but did not know if he received a response.

In his deposition, Kennedy explained that the PIP file is kept separate from the UIM file, and he did not have access to any medical bills or records submitted under Williams’s PIP claim. In addition, he never received nor requested authorization to access Williams’s medical bills and records, as he was unaware of their existence, and because it is not standard USAA practice to do so. Kennedy explained that neither the liability nor the PIP adjuster was allowed to disclose Williams’s medical information to the UIM adjuster without Williams’s express permission.

On November 11, 2019, Kennedy wrote Williams’s attorney asking for an update on the status of her treatment and UIM claim:

Your claim is unresolved because we are awaiting the resolution of Hannah Williams[’s] medical treatment and receipt of the medical records, bills, and other documentation for the evaluation of the potential [UIM]

claim. Please contact me to discuss the current treatment status of your client.

Williams’s attorney did not respond to the letter.

On December 10, 2019, Kennedy entered a file note stating, “file status – no change.” That same day, Kennedy sent another letter to Williams’s attorney requesting medical records and Williams’s current treatment status. Williams’s attorney again did not respond.

On January 13, 2020, Kennedy sent another letter to Williams’s attorney requesting information about her UIM claim:

Your claim is unresolved because we are currently monitoring the claim to determine if there will be [a UIM] claim for your client.

Please send us written verification of the underlying carrier’s limits.

If a [UIM] claim is presented, please provide us with the medical bills and records for the treatment your client received as a result of the injuries sustained in the motor vehicle accident. Once we have received written proof of the underlying carrier’s limits along with the medical bills and records, we will review your client’s claim for resolution.

As with the previous two letters, nothing in the record indicates that Williams’s attorney responded.

Having received no response from Williams or her attorney, Kennedy contacted the liability adjuster on February 4, 2020, who once again confirmed that the Parkers’ liability limits appeared to be adequate to compensate Williams. Based on that information, Kennedy provisionally closed Williams’s UIM claim that same day. The closing was administrative in nature, and it did not prevent or affect Williams’s ability to reopen the claim or USAA’s ability to evaluate it.

B

On June 25, 2021, Williams sued the Parkers and USAA. Williams’s complaint sought damages against the Parkers for negligence, and against USAA for breach of contract, alleging that Williams suffered damages exceeding the Parkers’ liability limits. Kennedy received a copy of the complaint on July 8, 2021.

On July 15, 2021, USAA issued discovery requests to Williams seeking information about her injuries before and after the accident, other medical conditions, incidents, and medical providers. 1 Williams provided responses on November 23, 2021. USAA replied that the information was incomplete and lacked specificity about the nature and cost of the future medical treatment Williams claimed she would need due to the accident.

On December 8, 2021, Williams sent a notice of claim under the IFCA to USAA, accusing it of “engaging in unfair claims practices in handling [Williams]’s injury claims and unreasonable denial and delay in paying benefits owed.” On December 15, 2021, USAA’s attorney wrote Williams’s attorney requesting authorization for the release of William’s medical records. The record does not include a response from Williams’s counsel. On January 24, 2022, USAA again wrote to Williams’s attorney asking for the release of her medical records:

On December 15, 2022[,] I sent authorizations for the release of plaintiff’s records and requested that your client sign and return them by December 29, 202[2,] so that we could collect her records. In that same letter I requested that you provide some dates when plaintiff is available to attend a deposition and that you supplement prior discovery responses if you

1 On September 22, 2021, Williams sent a policy limits demand letter to the Parkers. And on

October 25, 2021, the Parkers reached a settlement with Williams, tendering the $300,000 liability limits under their policy and obtaining a release of liability.

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Hannah Williams, V Usaa Casualty Insurance Company, (Wash. Ct. App. 2026).

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