In Jerymaine Beasley v. GEICO, 508 P.3d. 212, 2022 WL 1151426 (Wash App. Apr. 19, 2022, published in part), Division II of the court of appeals held “actual damages” under the Insurance Fair Conduct Act (“IFCA”) specifically include noneconomic damages (a component of which is emotional distress damages), a ruling completely at odds with and likely the death knell of Schreib v. Am. Family Mutual, 129 F. Supp. 3d 1129 (W.D. Wash. 2015).