Atain Specialty Insurance Company Missouri Cases

Appellant Franklin D. Allen appealed the circuit court's denial of his motion to set a trial date for bad faith claims against Atain Specialty Insurance Company. Allen had previously secured a $16 million judgment against an insured, Bryers, whom Atain refused to defend. The Supreme Court had modified a prior garnishment judgment against Atain to $1 million (policy limits) plus interest, explicitly stating no bad faith finding was made. The appellate court affirmed, holding that the Supreme Court's specific mandate on remand precluded the circuit court from addressing Allen's bad faith claims, as those issues were considered resolved within the traditional garnishment action.