of this situation is evident in the instant complaint, which refrains from charging FFG with negligence.) The majority of jurisdictions that have visited this question have concluded similarly, although these cases typically involve adjusters with a lesser degree of control over the claims-handling process than displayed in the case at bar. See, e.g., Hamill v. Pawtucket Mut. Ins. Co., 179 Vt. 250, 892 A.2d 226, 230 (2005) (“We concur with the majority view that public policy considerations do not favor creating a separate duty on the part of independent adjusters that would subject them to common law tort actions by insureds who have suffered econo . Bayless & Roberts, Inc., 608 P.2d 281, 287-88 (Alaska 1980) (similar); cf. Bass v. Cal. Life Ins. Co., 581 So.2d 1087, 1090 (Miss.1991) (<HOLDING>). This writer is not entirely unsympathetic to
holding prison official must have acted with reckless disregard for the inmates safety holding that a adjuster can only incur independent liability when his conduct constitutes gross negligence malice or reckless disregard for the rights of the insured holding that personal liability will only be imposed on a superior for his reckless disregard of a deputys known dangerous propensities holding that cjulpable negligence is negligence of a gross and flagrant character which evinces a reckless disregard for the safety of others holding that ordinary negligence and gross negligence are not separate causes of action