Castronovo-Flihan v. State Farm Mutual Automobile Insurance Company

District Court, D. Nevada·Decided November 20, 2023·No. 2:20-cv-01197·Unknown

Opinion

Nevada Bar No. 3062 Robert.Freeman@lewisbrisbois.com FRANK A. TODDRE, II Nevada Bar No. 11474 Frank.Toddre@lewisbrisbois.com 6385 S. Rainbow Boulevard, Suite 600 Las Vegas, Nevada 89118 702.893.3383 FAX: 702.893.3789 Attorneys for Defendant State Farm Mutual Automobile Insurance Company UNITED STATES DISTRICT COURT DISTRICT OF NEVADA, SOUTHERN DIVISION *** GINA CASTRONOVO-FLIHAN, CASE NO. 2:20-cv-1197-JCM-DJA Plaintiff, vs. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, a foreign company; AND DOES I through V, inclusive Defendants. Following pretrial proceedings in this case, pursuant to Local Rule 16-3 and 16-4, IT IS SO ORDERED: This is an action for Breach of Contract under Nevada’s common law. While the complaint originally held causes of action for Breach of the Covenant of Good Faith and Fair Dealing, and for violations of NRS § 686A.310, those causes of action were dismissed by a Partial Motion for Summary Judgement granted by this Court.1 The issues for trial are the allegations of State Farm’s unreasonable and improper conduct 1 in breaching the insurance policy with Plaintiff and Plaintiff’s damages, if any. A. Plaintiff’s Contentions 1. Plaintiff performed all conditions of the insurance policy. 2. Plaintiff was owed benefits under the insurance policy. 3. Defendant failed to provide the insurance benefits due and owing under the insurance policy. 4. Defendant breached the insurance policy by manufacturing reasons to deny the insurance benefits due and owing to Plaintiff under the insurance policy. 5. Defendant breached the insurance policy by making the claims process an adversarial or competitive process. 6. Defendant breached the insurance policy by relying upon insufficient, speculative and/or biased information. 7. Defendant breached the insurance policy by failing to acknowledge and act reasonable upon communication with respect to Plaintiff’s claim under the insurance policy. 8. Defendant breached the insurance policy by failing to adopt and implement reasonable standards for the prompt investigation and processing of claims. 9. Defendant breached the insurance policy by failing to promptly equate and communicate the evaluations to Plaintiff. 10. Defendant breached the insurance policy by failing to offer to Plaintiff what was owed. 11. Defendant breached the insurance policy by refusing to communicate with Plaintiff and perform an investigation as to her general damages for the evaluation. 12. Defendant breached the insurance policy by reducing Plaintiff’s claim by improperly basing her claim upon Medicare values for medical treatment through a claims software system. 13. Defendant breached the insurance policy by denying Plaintiff’s claim for the full policy limits. Plaintiff. 15. Defendant breached the insurance policy by delaying in its investigation and evaluation of the claim. 16. Defendant breached the insurance policy by denying the claim before completing an evaluation. 17. Defendant breached the insurance policy by training its adjusters to deny benefits by making unreasonably low offers that are below the evaluations. 18. Defendant breached the insurance policy by refusing to communicate its evaluation to Plaintiff. 19. Defendant breached the insurance policy by failing to provide an explanation of its offer and evaluation to Plaintiff. 20. Defendant breached the insurance policy by misrepresenting and improperly asserting that the in-person meeting between its adjuster and Plaintiff has to take place in a public library. 21. Defendant breached the insurance policy by failing to consider the new information of Plaintiff’s general damages after the in-person interview and increase the value of Plaintiff’s claim. 22. Defendant breached its promise for the bargain that when the insured, Plaintiff, was in need, Defendant, as the insurance company, will be there to help like a Good Neighbor. 23. Defendant breached the insurance policy by failing to pay Plaintiff a portion of the policy benefits commonly known as the impasse payment or undisputed amount. 24. Defendant breached the insurance policy by failing to offer the full value of the evaluations for the owed policy benefits. 25. Defendant breached the insurance policy by failing to give equal considerations to Plaintiff. 26. Defendant breached the insurance policy by failing to comply with policies 27. Defendant breached the insurance policy by delaying in its retention of experts. 28. Defendant breached the insurance policy by refusing to consider all of Plaintiff’s medical expenses without any medical expert opinion and/or notations in the claim file as to the basis for the denial. 29. Defendant breached the insurance policy by failing to consider any future general damages. 30. Defendant breached the insurance policy by failing to handle the claim in accordance with its own policies and procedures. 31. Defendant breached the insurance policy by failing to offer the full authority for the benefits owed to Plaintiff. 32. Defendant breached the insurance policy by failing to give a prompt and forthright explanation to Plaintiff as to the company’s position with respect to the claim. 33. Defendant breached the insurance policy by failing to conduct a diligent search for facts as promptly as possible. 34. Defendant breached the insurance policy by creating false or fictitious issues to avoid providing and/or paying benefits due and owing to Plaintiff. 35. Plaintiff has been forced to retain the services of an attorney in prosecution of the Complaint, incurring expensive legal fees, court costs, and for fees for other professionals for which Defendant is responsible B. Defendants’ Contentions Defendant contends that they did not breach the subject insurance policy contract, Policy Number #136 2037-F22-28. More specifically, Defendant contends the following: 1. Prior to the subject accident in 2019, Plaintiff experienced a separate motor vehicle accident related injury when she was rear-ended in March 2017, and experienced neck pain radiating to her arms, shoulder pain, headaches, and low back pain radiating to her legs. under Farmer’s Insurance. 3. Plaintiff Castronovo-Flihan’s complaint fails to state a cause of action against these answering defendants upon which relief can be granted. 4. Plaintiff Castronovo-Flihan did not fulfill her duty to cooperate with Defendant State Farm under the terms of the subject policy. 5. Defendant State Farm did not breach the terms of the subject policy, but instead simply requested a medical examination, as allowed under the terms of the subject policy, §6(a)(2). 6. Plaintiff’s remaining damages, if any, were actually and proximately caused by her prior 2017 Motor Vehicle Accident. 7. The valuation of the claim by State Farm Mutual Automobile Insurance Company was reasonable. 8. Defendant State Farm complied with the terms of the subject policy, case law, and Nevada statutes. 9. If any damages are proven in this case, the basis of those damages lies only with the breach of contract claim. 10. State Farm generally denies Plaintiff’s allegations set forth herein, and incorporates by reference the denials set forth in Defendant’s Answer to Plaintiff’s Complaint on file with the Court in this matter and raise the following affirmative defenses: (a) Plaintiff has failed to state a claim upon which relief could be granted. (b) Plaintiff failed to mitigate her damages. (c) The damages allegedly sustained by Plaintiff, if any, were not caused by any breach of contract or duty by Defendant State Farm Mutual Automobile Insurance Company, but rather by the acts or omissions of third persons who were not acting on behalf of Defendant State Farm Mutual Automobile Insurance Company (d) Defendant State Farm Mutual Automobile Insurance Company is that the complaint, and each and every purported claim for relief in said Complaint, is subject to a

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Castronovo-Flihan v. State Farm Mutual Automobile Insurance Company, (D. Nev. 2023).

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