Bennet v. State Farm Mutual Automobile Insurance

943 F. Supp. 821, 1996 WL 604755
CourtDistrict Court, N.D. Ohio
DecidedAugust 6, 1996
DocketNo. 5:94-CV-006
StatusPublished

This text of 943 F. Supp. 821 (Bennet v. State Farm Mutual Automobile Insurance) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bennet v. State Farm Mutual Automobile Insurance, 943 F. Supp. 821, 1996 WL 604755 (N.D. Ohio 1996).

Opinion

MEMORANDUM OF OPINION

O’MALLEY, District Judge.

The defendant in this case, State Farm Mutual Automobile Insurance Company, has moved for partial summary judgment, (docket #40), on the ground that the plaintiffs claim regarding the allegedly discriminatory denial of health insurance benefits to her is moot. For all of the reasons set forth more fully below, the defendant’s motion for partial summary judgment is GRANTED in part only and is, otherwise, DENIED.

I. Factual Background

The plaintiff in this case, who suffers from bipolar affective disorder, brings her claims under the Americans with Disabilities Act 42 U:S.C. § 12101 et seq. (“ADA”). With respect to the issue presented in the defendant’s most recent motion, the relevant facts are as follows.. The plaintiff was employed by the defendant from August 1, 1988 until September 30, 1992. During her employment, plaintiffs bipolar disorder was diagnosed. As a result of this condition, plaintiff took two leaves of absence, one in 1990 and another in 1992. During these leaves of absence, the plaintiff was hospitalized for her condition.

While away on leave in 1990, the plaintiff allowed her health insurance to lapse, due to nonpayment of premiums. When she returned to work, plaintiff reapplied for health insurance, but was required to show proof of insurability.1 Because the plaintiff was currently under treatment for bipolar disorder, a preexisting condition, she was unable to provide proof of insurability and was denied coverage.

In her complaint, plaintiff claims, inter alia, that the denial of her health insurance benefits was a violation of .the ADA. Plaintiffs claims were initially complicated by the fact that the ADA, which is not retroactive, did not become effective until July 26, 1992. Plaintiff was terminated from her employment on September 30, 1992. Similar to the arguments made by the defendant in its present motion for partial summary judgement, the defendant earlier argued for dismissal of the case on the ground that the plaintiff did not have standing to bring her claims because she has no justiciable stake in the litigation. Judge Bell found, however, [823]*823that, if the plaintiff incurred medical expenses in the two months during which she was employed by the defendant and the ADA was effective, which would have been reimbursed by her insurer but for the alleged discrimination, the plaintiff may have a sufficient interest in the outcome of the proceedings for standing purposes. (See Opinion of October 19,1994).

Discovery in this ease has revealed that plaintiff indeed incurred medical expenses that would have been paid by her insurer during the two months in question. On August 18, 1992 and September 15, 1992, plaintiff was billed for medical services provided twice during that time frame by Central Mental Health. However, these bills were adjusted by Central Mental Health and were written-off as not collectable on August 30, 1998.

Because these bills are no longer outstanding, it is now the defendant’s position, as stated in its motion for partial summary judgment, that plaintiff no longer has a “particularized stake” in this litigation and her claim for damages regarding the denial of health insurance to her is moot. In addition, defendant argues that any request for declaratory or injunctive relief with respect to this same claim also is moot because plaintiff is no longer employed by State Farm.

II. The Summary Judgement Standard

Rule 56(c) of the Federal Rules of Civil Procedure dictates that, where summary judgment is sought:

The judgment shall be rendered forthwith if the pleadings, depositions, answers to interrogatories and admissions on file, together with the affidavits, if any, show that there is no genuine issue of material fact and that the moving party is entitled to judgment as a matter of law.

While all evidence must be viewed in the light most favorable to the non-moving party, summary judgment is appropriate whenever that non-moving party fails to make a showing sufficient to establish the existence of an element essential to that party’s case and on which that party will bear the burden of proof at trial. Celotex Corp. v. Catrett, 477 U.S. 817, 322, 106 S.Ct. 2548, 2552, 91 L.Ed.2d 265 (1986).' “In other words, the movant [can] challenge the opposing party to ‘put up or shut up’ on a critical issue. After being afforded sufficient time for discovery, as required by Fed.R.Civ.P. 56(f), if the respondent [does] not ‘put up’, summary judgment [is] proper.” Street.v. J.C. Bradford & Co., 886 F.2d 1472, 1478 (6th Cir.1989). .

In this context, “the trial court no longer has a duty to search the entire record to establish that it is bereft of a genuine issue of material fact.” Street, at 1479-80 citing Frito-Lay Inc. v. Willoughby, 863 F.2d 1029, 1034 (D.C.Cir.1988). The trial court need not seek out factual disputes nor speculate on the possibility that, under some as yet unstated scenario, a meaningful factual dispute might somehow arise. The non-moving party is under an affirmative duty to point out specific facts in the record as it has been established, which create a genuine issue of material fact. See Fulson v. City of Columbus, 801 F.Supp. 1, 4 (S.D.Ohio 1992). Further, the non-movant must show more than a scintilla of evidence to overcome summary judgment; it is not enough for the non-moving party to show that there is some unspecified metaphysical doubt as to material facts. Id.

III. Analysis

Although the defendant assails the plaintiffs opposition to its motion on the ground that it does not set forth specific facts to contradict the defendant’s position, the issues presented by the defendant’s motion are primarily legal ones. It is defendant’s position that, because the plaintiff is no longer indebted on paper to Central Mental Health, she no longer has a “compensable claim”. Thus, defendant argues, any claim for damages resulting from the denial of medical benefits to the plaintiff, even if that denial was discriminatory, is now moot.

Defendant’s “mootness” argument fails to persuade for several reasons. First, the mere fact that Central Mental Health made a bookkeeping adjustment regarding plaintiffs account does not operate to wipe out plaintiffs ADA claim. The fact that plaintiff is no longer obligated, on paper, to pay the amounts she owed does not change [824]*824the fact that, the amount was never paid by the defendant, for allegedly discriminatory reasons, nor does it diminish any moral obligation on the plaintiffs part to pay what she owes. The arbitrary actions of an unrelated third party simply cannot suffice to snuff out plaintiffs ADA claim.

Second, defendant’s “mootness” argument misconstrues the nature of the damages available to a plaintiff under the ADA. 42 U.S.C. § 12117

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943 F. Supp. 821, 1996 WL 604755, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bennet-v-state-farm-mutual-automobile-insurance-ohnd-1996.