In Tippett v. Ameriprise Ins. Co., Civ. Action No. 14-4710, 2015 U.S. Dist. LEXIS 37513 (E.D. Pa. Mar. 25, 2015), the United States District Court for the Eastern District of Pennsylvania held that the Pennsylvania Supreme Court is unlikely to impose a duty of care for negligence claims brought by an insured on an independent insurance adjuster hired by the insured's insurance company.