"Policy Ensurance" 
The policyholder sued the insurance company for breach of unfair trade practices and
emotional distress because the insurance company would not pay the claim. The
judgment was in favor of the policyholder but the insurance company appealed and the
court reversed the decision. The court found that no private cause of action existed under
the Unfair Trade Practices Act (only for repeated offenses). The policyholder had
claimed a breach of fiduciary duty by the insurance company. The court found that the
relationship between the insurance company and the policyholder is not fiduciary in
nature:
Crossley v. Allstate Insurance Co., 400 N.W. 2d 625 Mich., 1986.
