FILED RATE DOCTRINE DEPENDS ON FILED RATES THAT ARE APPROVED:

THAT INCLUDES INSURANCE RATES.

Applying Third Circuit case law, the Court in Ainger v. Great Am. Assur. Co., No. 2020-0005, 2022 WL 4379794 (D.V.I. Sept. 22, 2022) required record proof that an insurance rate was filed with the appropriate regulatory agency before the Court could apply the filed-rate doctrine to insurance rates.  Ainger, 2022 WL 4379794, at *15.  The Court also  required proof that the insurance rate was actually approved in fact.

Moreover, the Court in this case applied settled law that the forum jurisdiction must have adopted the filed-rate doctrine in order for a federal court to apply it to claims based on the law of the forum.   Ainger, 2022 WL 4379794, at *14. 

Please read the disclaimer.  ©2022 Dennis J. Wall.  All rights reserved.