The Georgia Supreme Court clarified two important points of Georgia bad faith law. First, the Court clarified that an insurer does not have a duty to settle a claim within policy limits unless and until there is a valid offer from the claimant to do so.
Second, there must be a rejection of the offer to settle within policy limits before the insurer can be held liable for bad faith in refusing to accept it. In Hughes, the Supreme Court acknowledged that the June 2, 2009 letters constituted an offer to settle Hong and An’s claims. The letters, however, failed to specify when acceptance of the offer was required.