Hegarty v. Transamerica Life Insurance Company

CourtDistrict Court, N.D. California
DecidedJuly 15, 2020
Docket3:19-cv-06006
StatusUnknown

This text of Hegarty v. Transamerica Life Insurance Company (Hegarty v. Transamerica 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
Hegarty v. Transamerica Life Insurance Company, (N.D. Cal. 2020).

Opinion

1 2 3 4 IN THE UNITED STATES DISTRICT COURT 5 FOR THE NORTHERN DISTRICT OF CALIFORNIA 6 7 ROBERT HEGARTY, Case No. 19-cv-06006-MMC

8 Plaintiff, ORDER DENYING PLAINTIFF'S 9 v. MOTION FOR PRELIMINARY INJUNCTION 10 TRANSAMERICA LIFE INSURANCE COMPANY, Re: Doc. No. 21 11 Defendant. 12 13 Before the Court is plaintiff Robert Hegarty’s (“Hegarty”) Motion for Preliminary 14 Injunction, filed December 6, 2019.1 Defendant Transamerica Life Insurance Company 15 (“Transamerica”) has filed opposition, to which Hegarty has replied. Additionally, with 16 leave of court, both parties filed supplemental declarations and exhibits. The matter 17 came on regularly for hearing on July 10, 2020. Richard B. Glickman of Richard B. 18 Glickman APC appeared on behalf of Hegarty. Julie F. Wall of Chittenden, Murday & 19 Novotny LLC appeared on behalf of Transamerica. The Court, having considered the 20 papers submitted in support of and in opposition to the motion, as well as the arguments 21 of counsel at the hearing, hereby rules as follows. 22 BACKGROUND 23 The instant action is based on an alleged breach of a direct recognition life (“DRL”) 24 insurance policy Hegarty purchased in 1989 from Transamerica’s predecessor. Hegarty 25 claims he was guaranteed increases in cash values, generally known as “persistency 26 bonuses,” on the twentieth, thirtieth, and fortieth anniversaries of his policy’s issuance, 27 1 and that Transamerica declined to pay the thirtieth anniversary bonus, thus requiring him 2 to make additional payments in order to keep the policy in force. 3 DISCUSSION 4 By the instant motion, Hegarty seeks an order preliminarily enjoining Transamerica 5 from terminating coverage under his DRL insurance policy until a final adjudication of the 6 instant action. In response, Transamerica contends any such bonuses were 7 discretionary and, in any event, that any claims related thereto were released under the 8 terms of a nationwide class action settlement in Oakes v. Bankers United Life Assurance 9 Company, et al., Case No. 96-06849 (192nd Dist. Ct. Dallas Cty.) (“Oakes”). 10 “A preliminary injunction is an extraordinary remedy never awarded as of right.” 11 Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 24 (2008). “A plaintiff seeking a 12 preliminary injunction must establish that he is likely to succeed on the merits, that he is 13 likely to suffer irreparable harm in the absence of preliminary relief, that the balance of 14 equities tips in his favor, and that an injunction is in the public interest.” Id. at 20. As an 15 alternative to showing a likelihood of success on the merits, however, a plaintiff may 16 establish “that serious questions going to the merits [have been] raised,” provided such 17 plaintiff also establishes “a balance of hardships that tips sharply toward the plaintiff,” a 18 likelihood of irreparable harm, and that the injunction is in the public interest. See 19 Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1131, 1135 (9th Cir. 2011) 20 (internal quotation and citation omitted). 21 For the reasons stated in detail on the record at the hearing and summarized 22 below, the Court finds Hegarty’s claims are barred by the Oakes class action settlement 23 and, consequently, the first requirement for a preliminary injunction has not been met.2 24 2 In light of this finding, the Court does not address herein the additional 25 requirements for a preliminary injunction. See Winter, 555 U.S. 7, 20, 23-24, 26 (2008) (holding plaintiff seeking preliminary injunction must establish all four elements). As 26 Transamerica points out, however, Hegarty filed the instant motion over three years after Transamerica informed him it would not credit any future persistency bonuses (see 27 Hegarty Decl. Ex. N), which delay “undercut[s] [Hegarty]’s claim of irreparable harm,” see 1 The DRL insurance contract here at issue consists of a master policy, group 2 insurance certificate, and illustrations prepared for the policyholder. (See Hegarty Decl. 3 Ex. A.) The bonuses claimed in the instant action are referenced only in the illustrations. 4 The Oakes action concerned claims arising from illustrations provided in 5 connection with DRL insurance policies, and Hegarty, as a member of the class certified 6 in Oakes, released: 7 any and all causes of action, claims, . . . or rights, known or unknown, . . . 8 that have been, could have been, may be or could be alleged or asserted 9 now or in the future by . . . any Class Member . . . on the basis of, connected with, arising out of, or related to, in whole or in part, the Policies, 10 the Released Transactions and servicing relating to the Released Transactions, which include without limitation: . . . any or all of the . . . 11 illustrations or oral or written statements or representations allegedly made in connection with, or directly or indirectly relating to, the Released 12 Transactions, including, without limitation any acts, omissions, disclosures, 13 facts, matters, transactions, occurrences, or oral or written statements or representations relating to: . . . the Companies’ policies and practices 14 regarding . . . persistency, or other policy bonuses, . . . or any other matters relating to . . . persistency, or other policy bonuses . . . . 15 16 (See Hegarty Decl. Ex. J (Stipulation of Settlement) at § H.1.b.1 (emphasis added).) 17 Hegarty’s reliance on various other provisions in the Oakes settlement documents 18 is unavailing. In particular, along with a section in the Stipulation of Settlement that 19 provides “[n]either this Agreement nor any of the relief to be offered under the Stipulation 20 of Settlement shall be interpreted to alter in any way the contractual terms of any Policy” 21 (see id. at § M.21),3 Hegarty points to the “Notice of Class Action Settlement” and 22 “Answers to Questions Concerning the Proposed Settlement,” both of which state the 23 Oakes settlement “does not alter your contractual rights under the express terms of your 24

25 3 To the extent Hegarty, at the hearing, argued the Stipulation of Settlement constituted a novation by which his claims were preserved, the Court notes that the 26 above section reads in full: “Neither this Agreement nor any of the relief to be offered under the Stipulation of Settlement shall be interpreted to alter in any way the contractual 27 terms of any Policy or to constitute a novation of any Policy.” (See id. (emphasis 1 existing Policy” (see Hegarty Decl. Ex. G at § 5; Ex. H at § 6). As “Policy” or “Policies” is 2 defined in the Stipulation of Settlement to include “life insurance certificates” (see Hegarty 3 Decl. Ex. J at § A.57), and “certificates” include “any Illustrations” (see Hegarty Decl. Ex. 4 A, Ex. B), Hegarty argues, the word “Policy,” as used in the Oakes Stipulation of 5 Settlement, includes the illustrations, which, as noted, describe the bonuses Hegarty 6 claims are guaranteed. 7 Hegarty, however, fails to identify anywhere in his contract documents any 8 “contractual term,” let alone any “express term,” providing him with a guaranteed bonus. 9 Indeed, the only place the word “guaranteed” appears in connection with any bonus is in 10 the initial illustration, in reference to a “minimum interest column,” which column reflects a 11 consistent cash value of “0.” (See Hegarty Decl. Ex. B.)4 12 Moreover, in a section cited in passing by Hegarty, the Stipulation of Settlement, 13 after stating, consistent with the provisions on which Hegarty primarily relies, “[n]othing in 14 this Release shall be deemed to alter a Class Member’s rights . . .

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Waller v. Truck Insurance Exchange, Inc.
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Bluebook (online)
Hegarty v. Transamerica Life Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hegarty-v-transamerica-life-insurance-company-cand-2020.