Recently, in Baldwin v. Standard Fire Ins. Co., 2025 Ind. LEXIS 680 (Ind. Oct. 21, 2025), the Indiana Supreme Court addressed an insurance carrier’s options where insurance coverage is insufficient to satisfy multiple claimants and the dilemma faced by the insurance carrier in attempting to resolve such claims. Where an insurer is faced with multiple claims which are likely to exceed the available policy limits, what is an insurer to do? One option is to seek individual settlements, but this approach risks exhausting policy limits before satisfying all claimants. Another option is to refrain from individual settlements in hopes of attaining a global settlement, but this approach may fail and expose the insured to increased personal liability. Either option creates risks for the insured and thus exposes the insurer to a later claim that it breached its duty of good faith and fair dealing to its insured, or even that it acted in bad faith. In Baldwin, the insurer facing this dilemma filed an interpleader action naming all known claimants, depositing the policy limits with the trial court, and continued to defend its insured against all claims. In such circumstances, the Indiana Supreme Court held that such choice did not reach the insurer’s duty of good faith and fair dealing to its insured and did not amount to bad faith.