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Schmitt v. State Farm Auto Ins. Co.

Pennsylvania Superior Court

January 11, 2021

In Schmitt v. State Farm Ins. Co., State Farm appealed the trial court’s grant of partial summary judgment. Critically, the trial court resolved the appellee’s declaratory-judgment action but did not resolve the issue of damages. The Superior Court quashed the appeal as interlocutory and unreviewable. The Court analogized the case to Bolmgren v. State Farm Fire and Cas. Co., 758 A.2d 689 (Pa. Super. Ct. 2000). In both cases, the trial court resolved declaratory judgment claims upon the parties’ competing motions for summary judgment. But here, as in Bolmgren, the trial court did not yet resolve Appellee’s claims related to damages. Therefore, State Farm’s appeal was interlocutory.

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