The appeals court disagreed. Fridman, it said, was an uninsured motorist case, and its logic does not transfer cleanly to property claims. In a UM case, a jury can find damages well above policy limits and the insured can pursue that excess later. Property insurance offers no such path. So the verdict settles the contract damages only – it does not block a separate claim for extra-contractual damages from bad faith, such as interest, costs, and fees. Those, the court added, could not have been raised in the contract trial anyway, because claims-handling evidence is barred there.
