Defendant insurer sought review of a judgment of the Superior Court of Sacramento County (California), which awarded compensatory damages, punitive damages and attorney fees to plaintiff insured for breach of contract to provide disability benefits, and for the “bad faith” denial of benefits.
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Overview
Plaintiff insured sued defendant insurer for breach of contract to provide disability benefits, and defendant’s “bad faith” denial of benefits. A jury awarded plaintiff compensatory damages and punitive damages. Pursuant to a stipulation, the issue of “damages” in the form of attorney fees was tried to the trial court without a jury, and the trial court awarded attorney fees to plaintiff. Defendant asserted that a number of the trial court’s evidentiary rulings and certain jury instructions were erroneous, that the punitive damage award was excessive, and that plaintiff could not recover attorney fees. The court affirmed the judgment of the trial court except for the award of attorney fees, which was reversed, because there was no basis for the award of attorney fees. The court held that evidence of other claims that plaintiff used to establish defendant’s claims application practices was properly admitted. The court also held that the jury instructions given by the trial court were not erroneous, and that the punitive damage award was not excessive or improper.
Outcome
The court affirmed the trial court’s judgment for plaintiff insured in her action for breach of contract to provide disability benefits, and for the “bad faith” denial of benefits, and the rulings of the trial court, except for the award of attorney fees, for which there was no basis, because plaintiff’s evidence was properly admitted, the jury instructions were not erroneous, and the punitive damage award was not excessive or improper.
