Pat Forth, Individually and on Behalf of Others Similarly Situated v. Allstate Indemnity Company
Pat Forth sued Allstate Indemnity Company after her daughter's automobile accident, alleging Allstate arbitrarily paid only a portion of medical expenses using a computerized database (MBRS) and an eighty-fifth percentile standard, rather than 'reasonable' expenses. Forth initially sought both retrospective relief for past claims and prospective relief to enjoin future use of MBRS, but later removed requests for monetary damages. The trial court dismissed the suit for lack of standing. On appeal, the court held that Forth lacked standing for prospective relief because she was no longer an Allstate insured. However, the appellate court found Forth had standing for retrospective relief regarding her past claims, asserting that an injury existed due to Allstate's alleged failure to pay reasonable expenses as per the policy. Consequently, the trial court's dismissal was vacated regarding past claims and remanded for further proceedings.