Campa v. United of Omaha Life Insurance Company

CourtDistrict Court, N.D. California
DecidedMay 27, 2025
Docket5:24-cv-00576
StatusUnknown

This text of Campa v. United of Omaha Life Insurance Company (Campa v. United of Omaha Life Insurance Company) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Campa v. United of Omaha Life Insurance Company, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 CORINA CAMPA, Case No. 24-cv-00576-NW

8 Plaintiff, ORDER DENYING CROSS MOTIONS 9 v. FOR SUMMARY JUDGMENT

10 UNITED OF OMAHA LIFE INSURANCE Re: ECF Nos. 64, 71 COMPANY, 11 Defendant.

12 13 Plaintiff Corina Campa (“Plaintiff” or “Campa”) sued Defendant United of Omaha Life 14 Insurance Company (“Defendant” or “United”) alleging breach of contract and breach of the 15 implied covenant of good faith and fair dealing for unpaid life insurance death benefits. Compl., 16 ECF No. 1. Defendant answered the complaint. Answer, ECF No. 29. Plaintiff moved for 17 summary judgment. Plaintiff’s Mot. for Summary Judgment, ECF No. 64 (“Campa MSJ”). 18 Defendant filed an opposition and simultaneously filed a cross-motion for summary judgment. 19 Defendant’s Mot. for Summary Judgment and Opp’n to Campa MSJ, ECF No. 71 (“United 20 MSJ”). The parties filed respective oppositions and replies to the cross-motions for summary 21 judgment. ECF Nos. 76, 78. 22 Having considered parties’ briefing and the relevant legal authority, the Court finds this 23 matter suitable for resolution without oral argument. Civil Local Rule 7-1(b). The Court DENIES 24 Plaintiff’s motion for summary judgment and DENIES Defendant’s cross-motion for summary 25 judgment. 26 I. BACKGROUND 27 Campa is a resident of San Jose, California. Compl., ¶ 3. United is a Nebraska 1 the Court has personal jurisdiction over Defendant and subject matter jurisdiction over Plaintiff’s 2 claims. Compl., ¶ 1; Answer, ¶ 1. 3 In December 2020, Campa worked with a United agent to apply for an individual life 4 insurance policy for her now-deceased son, Juan Carlos Campa. Campa MSJ at 1; United MSJ at 5 3. United alleges (and Campa does not admit) that on the application Campa answered “no” to a 6 question asking, “[i]n the past 12 months, has the Proposed Insured used any form of tobacco[?]” 7 United MSJ at 1. Campa maintains that Mr. Campa “never smoked or used tobacco products.” 8 Campa MSJ at 9. In January 2021, United approved the application and issued Campa an 9 “Express Life Policy,” No. BU3032410, with a $100,000 death benefit. Campa MSJ at 5; United 10 MSJ at 3. 11 Approximately ten months later, on November 12, 2021, Mr. Campa died. Campa MSJ at 12 5; United MSJ at 4. Campa notified United of Mr. Campa’s death. United informed Campa that 13 because the policy was less than two years old it qualified as a “contestable claim,” and United 14 was permitted to verify the answers submitted on the December 2020 application. Id. 15 United has a team of employees, called the “FOCAS Team,” whose duties include 16 investigating and deciding contestable claims. Id. Additionally, for contestable claim 17 investigations involving a policy with a death benefit of $100,000, United has a second team, 18 called the Risk Team, that reviews for whether there was a misrepresentation on the application, 19 and if so, if the misrepresentation would have affected how or whether United would have issued 20 the policy. Campa MSJ at 6; United MSJ at 5. 21 As part of the contestable claim verification process, United obtained and reviewed 22 medical records from Regional Medical Center of San Jose. Campa MSJ at 5; United MSJ at 5. 23 United reviewed a July 26, 2020 emergency room treatment note, which contained the following 24 language in the “initial assessment” section: “Smoking status for patients 13 years old or older: 25 Current some day smoker.” Id. United received multiple additional medical records for Mr. 26 Campa for the period between December 30, 2015, to January 30, 2021. Compl. ¶ 41; Answer ¶ 27 41. These records report that Mr. Campa’s smoking status was “unknown” or that he was a “never 1 United acknowledges that its policy is to “assume that information in medical records is 2 accurate, and United assumed that the ‘current some day smoker’ entry in the Regional MC 3 records was accurate.” United MSJ at 11; see also Campa MSJ at 12. 4 On April 18, 2023, United wrote Campa a letter explaining that United had rescinded 5 Campa’s policy. The letter stated, in part: 6 Medical records from Regional Medical Center note Juan Campa was a smoker. We also received a statement from the producer. He 7 confirmed he only met with Corina Campa. Corina Campa was the one answering the applications questions and that he never met with 8 Juan Campa. Mr. Campa did not sign the application, as required by our underwriting guidelines. 9 Based on this information, we found that Juan Carlos Campa 10 answered questions [about] tobacco/nicotine use incorrectly and did not sign the application. Had we been aware of Juan Carlos Campa’s 11 condition and treatment at the time the policy was applied for, we would not have issued the policy. The contract, therefore, is being 12 rescinded. . . . Our refund of $960.00 for the premiums paid is enclosed. 13 If you have any questions about this decision, or if you have any other 14 information you wish us to consider, please let us know. We will be happy to review any additional information you submit. Our toll free- 15 number is (800) 775-6000. 16 Campa MSJ at 9; United MSJ at 8-9. 17 In June 2023, Campa secured counsel and requested that United share materials related to 18 its investigation and denial of her claim. Campa MSJ at 9-10; United MSJ at 9. Campa 19 additionally returned the premium refund check to United. Id. Following Campa’s letters, United 20 initiated a reconsideration of the rescission decision. Campa MSJ at 10; United MSJ at 10. 21 United acknowledged that the rescission decision was based on two grounds: United’s 22 understanding that (1) Mr. Campa did not sign the application, and (2) that there was a material 23 misrepresentation in the application. Campa MSJ at 10-11; United MSJ at 10. On September 8, 24 2023, United wrote to Campa and her counsel, stating: 25 [A]fter further investigation and based on the information provided in your letter, we have determined that the rescission based on the failure 26 of Mr. Campa to sign the application should be reversed. . . . However, the application contained a material misrepresentation when it stated 27 that Mr. Campa had not used tobacco in the 12 months before the 1 Campa MSJ at 11; United MSJ at 11. United maintains that rescission of the policy is appropriate 2 based on the alleged material misrepresentation Campa made in the policy application, namely 3 that Mr. Campa smoked in the year prior to the application. United MSJ at 2. 4 II. LEGAL STANDARD 5 A court shall grant summary judgment “if . . . there is no genuine dispute as to any material 6 fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). The burden 7 of establishing the absence of a genuine issue of material fact lies with the moving party, see 8 Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986), and the court must view the evidence in the 9 light most favorable to the non-movant. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 10 (1986) (citation omitted). A genuine issue of material fact exists if there is sufficient evidence 11 such that a reasonable jury could return a verdict for the non-moving party. Id. at 248. The Court 12 may not weigh the evidence, assess the credibility of witnesses, or resolve issues of fact. See id. at 13 249.

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Campa v. United of Omaha Life Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/campa-v-united-of-omaha-life-insurance-company-cand-2025.