Woods v. Allstate Property and Casualty Insurance Company, No. A26A1623, 2026 WL 2728807, __ S.E.2d __ (Ga. Ct. App. Sept. 16, 2026). The court (Padgett, J.; McFadden, P.J., and Watkins, J., concur) affirms dismissal of contract, bad faith, and related claims against an uninsured-motorist carrier. The insureds sued after their tort action was dismissed as to the alleged uninsured driver without a judgment establishing liability. Id. at **1–2. The court held that recovery against the carrier depended on first obtaining a judgment against the tortfeasor; relabeling claims as breach of contract or unfair trade practices did not avoid that condition. A pre-judgment demand can start the 60-day period under OCGA § 33-7-11(j), but does not eliminate the judgment requirement. Because the complaint showed that the condition was unmet, dismissal was proper. Id. at **2–4.
