Jenna Ockford v. Encompass Insurance Co

Court of Appeals for the Third Circuit·Decided June 22, 2026·No. 25-1724·Unpublished

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 25-1724 ____________

JENNA OCKFORD; JUSTIN HERBST, Appellants

v.

ENCOMPASS INSURANCE COMPANY ____________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. Civil No. 2:24-cv-01581) Magistrate Judge: Honorable Elizabeth T. Hey ____________

Submitted Under Third Circuit L.A.R. 34.1(a) on March 17, 2026

Before: MATEY, FREEMAN, and CHUNG, Circuit Judges

(Opinion filed: June 22, 2026)

_______________

OPINION * _______________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. FREEMAN, Circuit Judge.

Jenna Ockford and her husband Justin Herbst (collectively, “Plaintiffs”) appeal the

District Court’s grant of summary judgment on their bad faith claim against their motor

vehicle insurance provider, Encompass Insurance Co. (“Encompass”).1 We will affirm

the judgment.

I.

On December 16, 2022, Plaintiffs were struck by a motor vehicle while walking

across a street in Newtown, Pennsylvania. Herbst hit his head on the asphalt and briefly

lost consciousness. Ockford landed on her buttocks and back. Plaintiffs both went to the

hospital by ambulance.

At the hospital, Ockford complained of back and elbow pain. Scans of her back

showed a fracture of her fourth lumbar vertebrae that was “probably chronic in nature,”

but no acute fractures or malalignment. App. 123. No scans were taken of her elbow,

and she was released that day. Herbst stayed at the hospital overnight after scans of his

head showed he had subdural hematomas and a skull fracture.

Six days after the accident, Plaintiffs reported the accident to Encompass and gave

the company contact information for their attorney (“Counsel”). Plaintiffs’ policy with

Encompass provided up to $200,000 per person in underinsured motorist (“UIM”)

1 By consent of the parties, a United States Magistrate Judge sat as the District Court. See 28 U.S.C. § 636(c).

2 benefits. Encompass later learned that the driver of the vehicle that struck Plaintiffs had a

policy from another insurer with liability limits of $25,000 per person.

On January 9, 2023, Encompass’s claims adjuster provided her contact

information to Counsel. On January 13, the adjuster called Counsel’s office to request

information about Plaintiffs’ treatment and injuries. On January 16, Counsel’s paralegal

told the adjuster that the paralegal had no updated information, and the adjuster said she

would follow up in thirty days.

Thirty days later, the adjuster called and emailed Counsel to request details about

Plaintiffs’ injuries, treatment, billing, and wage loss. The adjuster continued to call and

email Counsel repeatedly over the next six months. She received no information from

Counsel’s office until July 2023, when Counsel’s paralegal reported by telephone that

Plaintiffs were still receiving treatment for their injuries.

In August 2023, the adjuster emailed Counsel to request specifics about Plaintiffs’

injuries and treatment. In September 2023, Counsel’s paralegal spoke to the adjuster and

reported that Ockford had sustained a non-surgical elbow fracture and was seeing a

chiropractor for lumbar spine symptoms, and Herbst had non-surgical head and neck

injuries although his treatment status was unknown. Counsel’s office did not send the

adjuster any records.

In October 2023, Counsel informed the adjuster that Plaintiffs would be settling

their claim against the driver’s insurance company and had accepted the driver’s policy

limit of $25,000 for each of them. Counsel also confirmed that Plaintiffs were pursuing

UIM benefits from Encompass.

3 In December 2023, nearly a year after the accident, the adjuster received a first

round of records to support Plaintiffs’ UIM claims. Stating that more records would

follow, Counsel provided records from Ockford’s emergency room visit on the date of

the accident, her follow-up visit with an orthopedist a week later, and five visits to a

chiropractor in April 2023. These records included no diagnosis of an elbow fracture and

no information about lost wages or out-of-pocket expenses. As to Herbst, Counsel

provided records from the post-accident hospital visit, a visit with an orthopedist a week

later, and a primary care visit in February 2023.

Two days after receiving those records, the adjuster extended offers to Plaintiffs

“based upon the information available at this time” and stated that she would reevaluate

the offers based on any additional documentation she received from Counsel. Supp. App.

563. After reducing her valuation of each claim by $25,000 to account for the amounts

Plaintiffs received from the driver’s insurance company, the adjuster offered $10,000 to

resolve Herbst’s claim and $3,000 to resolve Ockford’s claim.

In January 2024, Counsel sent the adjuster records documenting a medical lien for

Herbst and Ockford’s diagnosed elbow fracture. Six days later, based on the new

documentation, the adjuster increased her offers to $34,000 for Herbst and $18,000 for

Ockford. Again, the claims valuations were offset by the payments from the driver, and

the adjuster stated that she would consider any additional documentation she received

from Counsel. The adjuster received no response, so she followed up in February 2024.

In March 2024, Counsel sent the adjuster additional medical records and wage loss

documentation, demanded the $200,000 policy limits each for Ockford and Herbst, and

4 threatened to sue Encompass if the matter was not resolved in two weeks. One week

later, based on the new documentation, the adjuster sent Counsel increased offers of

$91,000 for Herbst and $32,500 for Ockford. In her correspondence, she included a list

of the additional treatment records, wage documentation, and radiological reports and

films that she sought to support the claims.

In April 2024, without responding to the adjuster’s document requests, Plaintiffs

sued Encompass. As relevant here, they claimed that Encompass acted in bad faith in

violation of Pennsylvania law, and they sought punitive damages, interest, costs, and

attorney’s fees. See 42 Pa. C.S. § 8371.2

The District Court granted summary judgment to Encompass on the bad faith

claim. After the court entered final judgment, Plaintiffs timely appealed.

II3

To prevail on a bad faith insurance claim under Pennsylvania law, “a plaintiff

must demonstrate, by clear and convincing evidence, (1) that the insurer did not have a

reasonable basis for denying benefits under the policy and (2) that the insurer knew or

2 The parties settled Herbst’s UIM claim while the litigation was pending. Plaintiffs did not amend their complaint to make any allegations about events post-dating the initial filing. 3 The District Court had jurisdiction under 28 U.S.C. § 1332. We have jurisdiction pursuant to 28 U.S.C. § 1291. We review a district court’s grant of summary judgment de novo. Le Pape v. Lower Merion Sch.

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