Navashia Akins v. State Farm Mutual Automobile Insurance Company

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

NAVASHIA AKINS PLAINTIFF

v. No. 4:25-cv-887-DPM

STATE FARM MUTUAL AUTOMOBILE DEFENDANT I NSURANCE COMPANY

ORDER Akins’s motion for leave to amend is denied. Leave to amend should be freely granted, but not when the amendments would be futile. Zutz v. Nelson, 601 F.3d 842, 850–51 (8th Cir. 2010). Her proposed bad faith claim still does not clear Arkansas’s high bar. Doc. 20 at 1–2; Southern Farm Bureau Casualty Insurance Co. v. Allen, 326 Ark. 1023, 1026–27, 934 S.W.2d 527, 529 (1996). And Arkansas doesn’t recognize a tort claim for the negligent handling of insurance contracts. Farm Bureau Insurance Co. of Arkansas v. Running M Farms, Inc., 366 Ark. 480, 490–93, 237 S.W.3d 32, 39–42 (2006). Akins’s motion to compel is denied, too. State Farm has said it would produce her claim file. Plus Akins hasn’t shown any risk of destruction or spoliation. Motions, Doc. 22 & 26, denied. So Ordered.

D.P. Marshall Jr. United States District Judge

12 January 2026

_2-