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Applying Montana state law, the United States District Court for the District of Montana has held that an insurer has no duty to interplead its policy limits to satisfy claims by multiple competing claimants and did not violate Montana’s Unfair Trade Practices Act (“UTPA”) when successively settling claims of multiple plaintiffs. Amberg v. Travelers Cas. & Sur. Co. of Am., 2025 WL 1811459 (D. Mont. July 1, 2025).
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