Ohio Supreme Court Clarifies Attorney-Client Privilege in Insurance Bad-Faith Cases

On February 26, 2026, the Supreme Court of Ohio issued its opinion in Eddy v. Farmers Property Cas. Ins. Co., clarifying when an insurer is entitled to assert the attorney-client privilege and work-product doctrine in bad faith litigation. The Court held that materials in an insurer’s claim file, that are protected by the attorney-client privilege, are only subject to disclosure if the plaintiff makes a prima facie showing of bad faith. Work-product materials within the claim file are subject to... By: Dinsmore & Shohl LLP