Bansal v. Nationwide Mutual Insurance Company

District Court, N.D. California·Decided August 10, 2025·No. 3:23-cv-05527·Unknown

Opinion

San Francisco Division RAKESH BANSAL, et al., Case No. 23-cv-05527-LB

Plaintiffs, ORDER GRANTING SUMMARY v. JUDGMENT

NATIONWIDE MUTUAL INSURANCE Re: ECF No. 53 COMPANY, Defendant. In this insurance-coverage action, the parties dispute whether defendant Nationwide Mutual Insurance Company paid full insurance benefits to the plaintiffs, Rakesh and Hema Bansal, after a water accident damaged their home. Nationwide ultimately paid the cost of repairs after a contractually required appraisal. It did not pay other costs: moving costs, living expenses for food and housing, and fair rental value. It moved for summary judgment on the grounds that it paid covered losses, which did not include the other expenses, there is no bad-faith claim because it paid and never unreasonably withheld benefits, and punitive damages thus are not warranted. Summary judgment is granted on all grounds. The next sections summarize (1) the policy, (2) the loss and investigation, and (3) relevant procedural history. 1. The Policy The policy for the plaintiff’s house has the following loss provisions. A. Coverage A — Dwelling 1. We cover: a. The dwelling on the “residence premises” shown in the Declarations, including structures attached to the dwelling; and b. Materials and supplies located on or next to the “residence premises” used to construct, alter or repair the dwelling or other structures on the “residence premises.” . . . . D. Coverage D — Loss of Use . . . . 1. Additional Living Expense If a loss covered under Section I makes that part of the “residence premises” where you reside not fit to live in, we cover any necessary increase in living expenses incurred by you so that your household can maintain its normal standard of living. Payment will be for the shortest time required to repair or replace the damage or, if you permanently relocate, the shortest time required for your household to settle elsewhere. Payment will not exceed the actual loss sustained or 24 months from the date of loss, whichever occurs first. 2. Fair Rental Value If a loss covered under Section I makes that part of the “residence premises” rented to others or held for rental by you not fit to live in, we cover the fair rental value of such premises less any expenses that do not continue while it is not fit to live in. Payment will be for the shortest time required to repair or replace such premises. Payment will not exceed the actual loss sustained or 24 months from the date of loss, whichever occurs first. . . . . C. Duties After Loss In case of a loss to covered property, we have no duty to provide coverage under this policy if you or an “insured” seeking coverage fails to comply with the following . . . . 5. Cooperate with us in the investigation of a claim; . . . . 8. Send to us, within 60 days after our request, your signed, sworn proof of loss which sets forth, to the best of your knowledge and belief: . . . . g. Receipts for additional living expenses incurred and records that support the fair rental value loss; . . . . F. Appraisal If you and we fail to agree on the amount of loss, either may demand an appraisal of the loss. . . . The appraisers will separately set the amount of loss. . . . A decision agreed to by any two will set the amount of loss. . . . . The appraisers and umpires are only authorized to determine the “actual cash value,” replacement cost, or cost to repair the property that is the subject of the claim.1 . . . . “Actual Cash Value” means the amount it would cost the “insured” to repair or replace covered property in its condition at the time of the loss, such expense being computed as of the time of the loss and quantified as follows. The measure of this “actual cash value” recovery, in whole or partial settlement of the claim, for either a total or partial loss to the structure or its contents, shall be the amount it would cost the “insured” to repair, rebuild, or replace the thing lost or damaged less a fair and reasonable deduction for physical depreciation based on its condition at the time of the loss or the policy limit, whichever is less. A deduction for physical depreciation shall apply only to components of a structure that are normally subject to repair and replacement during useful life of that structure.2 2. The Loss and Investigation On July 19, 2021, Mr. Bansal reported water damage in his home from a July 17 leak in a refrigerator line. Nationwide’s adjuster Robert Mulcahey, based in Iowa and not a California-

1 Policy, Ex. A to Lathrum Decl. – ECF No. 53-3 at 20 (Bates NMIC_000014), 23 (Bates NMIC_000017), 36–39 (Bates NMIC_000030–33) (cleaned up). Citations refer to the Electronic Case File (ECF); pinpoint citations are to the ECF-generated page numbers at the top of documents. licensed contractor, hired Alacrity, a third-party vendor, to inspect the damage.3 Alacrity charged $300.06. Alacrity vets its adjusters for experience, certifications, and licenses but does not provide training. It did not know its adjuster’s training or qualifications.4 On July 28, 2021, Nationwide sent its initial repairs estimate ($11,845.44 for replacement costs and $11,068.13 for actual cash value), paid Mr. Bansal $8,568.13 (the amount after the policy deductible and depreciation), and explained how to request additional payment for other necessary repair work.5 In August, the plaintiffs retained a public adjuster, Jahn Miller, in exchange for ten percent of any Nationwide payment. Mr. Miller and Mr. Mulcahey communicated about the scope of work and covered living expenses, including Mr. Mulcahey’s ability to pay hotel expenses directly or via reimbursement. Mr. Miller’s contractor, Tom Koester, inspected the property and took measurements but did not perform destructive testing. He identified additional damage and suggested that Nationwide should reinspect the property. Mr. Mulcahey scheduled a reinspection with Alacrity for October 26, 2021, so that Mr. Bansal could be present. On September 20, 2021, Mr. Koester sent Mr. Miller a preliminary replacement estimate of $140,905.69 that included replacement of the wood floor because of its age and thinness, though he did not measure the thickness or know how often it had been refinished.6 Mr. Miller sent the estimate to Nationwide on October 21, 2021, before the October 26 inspection.7

Free access — add to your briefcase to read the full text and ask questions with AI

Bansal v. Nationwide Mutual Insurance Company, (N.D. Cal. 2025).

Bansal v. Nationwide Mutual Insurance Company (Bansal v. Nationwide Mutual Insurance Company) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Marbury v. Brooks
20 U.S. 556 (Supreme Court, 1822)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Devereaux v. Abbey
263 F.3d 1070 (Ninth Circuit, 2001)
Oasis West Realty v. Goldman
250 P.3d 1115 (California Supreme Court, 2011)
Waller v. Truck Insurance Exchange, Inc.
900 P.2d 619 (California Supreme Court, 1995)
Foster-Gardner, Inc. v. National Union Fire Insurance
959 P.2d 265 (California Supreme Court, 1998)
Klubnikin v. California Fair Plan Assn.
84 Cal. App. 3d 393 (California Court of Appeal, 1978)
Belz v. Clarendon America Insurance
69 Cal. Rptr. 3d 864 (California Court of Appeal, 2007)
CHATEAU CHAMBERAY HOA v. Associated Internat. Ins. Co.
108 Cal. Rptr. 2d 776 (California Court of Appeal, 2001)
Tomaselli v. Transamerica Insurance
25 Cal. App. 4th 1269 (California Court of Appeal, 1994)
MacKinnon v. Truck Insurance Exchange
73 P.3d 1205 (California Supreme Court, 2003)
Wilson v. 21st Century Insurance
171 P.3d 1082 (California Supreme Court, 2007)