Goauto Insurance Company v. 2B Claims Services Inc.

── Goauto Insurance Company v. 2B Claims Services Inc. ── Court: Court of Appeals for the Eleventh Circuit Date: June 08, 2026 Category: NEW USCA11 Case: 24-13643 Document: 59-1 Date Filed: 06/08/2026 Page: 1 of 19 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-13643 ____________________ GOAUTO INSURANCE COMPANY, Plaintiff-Appellant, versus 2B CLAIMS SERVICES INC., Defendant-Appellee. ____________________ Appeal from the United States District Court for the Northern District of Florida D.C. Docket No. 5:23-cv-00188-AW-MJF ____________________ Before BRANCH, GRANT, and HULL, Circuit Judges. HULL, Circuit Judge: GoAuto Insurance Company hired 2B Claims Services Inc. to adjust claims arising from a four-car collision caused by GoAuto’s insured’s daughter. Two injured claimants made an offer to settle their claims for the $15,000 per-person policy limits USCA11 Case: 24-13643 Document: 59-1 Date Filed: 06/08/2026 Page: 2 of 19 2 Opinion of the Court 24-13643 ($30,000 total) with checks in hand by December 14, 2020. GoAuto agreed to pay the policy limits but insisted on signed releases before it would send the checks. The claimants repeated their demand for checks in hand by December 14. GoAuto let the December 14 deadline pass without sending the checks. Later on, the claimants threatened to sue GoAuto for bad-faith refusal to timely send the checks paying the policy limits. Before any lawsuit was filed, GoAuto settled with the claimants for about $200,000 above the policy limits. GoAuto then sued 2B, blaming 2B for not advising GoAuto about the legal risk of exposure to excess liability for bad-faith conduct. The district court granted summary judgment for 2B, determining, inter alia, that (1) 2B did not breach any duty it owed to GoAuto because giving legal advice to GoAuto about excess liability for bad-faith conduct was outside the purview of 2B as a claims adjuster in this case, and (2) in any event, GoAuto’s decision not to send the settlement checks by the December 14 deadline was the cause of GoAuto’s alleged damages, not 2B’s conduct. GoAuto appealed. After careful review and with the benefit of oral argument, we agree and affirm the grant of summary judgment. I. FACTS A. Policy and Accident GoAuto is a Louisiana-based insurer that sells policies in Louisiana, Ohio, Nevada, and Texas. GoAuto provided Louisiana car insurance to Alisha Hill, the insured. Hill’s policy had bodily injury limits of $15,000 per person and $30,000 per accident. On USCA11 Case: 24-13643 Document: 59-1 Date Filed: 06/08/2026 Page: 3 of 19 24-13643 Opinion of the Court 3 July 31, 2020, Alisha’s daughter, Kayranasia Hill, was involved in a four-car pileup in Panama City Beach, Florida, while driving Alisha’s car. B. GoAuto’s Relationship with 2B GoAuto retained 2B to provide services related to the July 31 collision. GoAuto’s adjuster, Frank “Chip” Collura, was 2B’s point of contact. There was no written contract between GoAuto and 2B. Rather, Collura testified that 2B’s job was to “[d]o the things that an adjuster would do”