Panel: ‘Relation Back’ Doctrine Does Not Render Claims Against Insurer Timely

(March 27, 2018, 1:33 PM EDT) -- SALT LAKE CITY — A Utah appeals panel on March 22 held that a lower court properly denied a convenience store insured’s motion to amend its complaint to add breach of contract and bad faith claims against its insurer in a dispute over an employee theft, finding that the "relation back" doctrine does not save the untimely claims (The Frugal Flamingo Quick Stop v. Farm Bureau Mutual Insurance Company, No. 20160540, Utah App., 2018 Utah App. LEXIS 50)....

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