John Boaden, et al. v. Continental Casualty Company

CourtDistrict Court, N.D. Illinois
DecidedFebruary 6, 2026
Docket1:23-cv-01477
StatusUnknown

This text of John Boaden, et al. v. Continental Casualty Company (John Boaden, et al. v. Continental Casualty Company) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Boaden, et al. v. Continental Casualty Company, (N.D. Ill. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

JOHN BOADEN, et al., No. 18 CV 3314 Plaintiffs, No. 20 CV 5127 No. 21 CV 2349 v. No. 21 CV 4010 No. 23 CV 1477 CONTINENTAL CASUALTY COMPANY, Judge Georgia N. Alexakis Defendants.

MEMORANDUM OPINION AND ORDER

John Boaden and the other named plaintiffs in five related cases (collectively, “plaintiffs”) purchased long-term care insurance from Continental Casualty Company (“Continental”) through their employers.1 After Continental began raising rates on a state-by-state basis, plaintiffs sued, seeking to represent various classes of policy holders who were affected by the rate changes, under the theory that the state-by- state rate change violated a promise by Continental to only raise rates uniformly for the entire “premium class,” which plaintiffs assert means all policyholders nationwide. Plaintiffs now move for class certification. [132], [163].2 Two additional motions have also been filed: Continental moves to exclude the testimony of Roger Loomis, an expert for plaintiffs, [156], [161], and the American Council of Life

1 The five related cases are: Gunn, et al. v. Continental Casualty Company, No. 18 CV 3314 (N.D. Ill.); Sieving, et al. v. Continental Casualty Company, No. 20 CV 5127 (N.D. Ill.); Brown, et al. et v. Continental Casualty Company, No. 21 CV 2349 (N.D. Ill.); Cheslow, et al. et v. Continental Casualty Company, No. 21 CV 4010 (N.D. Ill.), and Boaden, et al. et v. Continental Casualty Company, No. 23 CV 1477 (N.D. Ill.). 2 Docket citations are to Boaden, No. 23 CV 1477, unless otherwise noted. Insurers and the American Property Casualty Insurance Association move for leave to file an amicus brief, [169]. For the following reasons, the Court denies all motions.

I. Background The parties agree on the basic history of the case. Continental provides long- term care insurance policies to cover expenses like assisted living, adult daycare centers, or skilled nursing facilities. [88] ¶ 61. Continental issued these policies nationwide. Id. ¶ 242. Long-term care coverage policies can last for decades; for example, plaintiff Boaden purchased a certificate of coverage in 1994 and has paid premiums to Continental since that date, id. ¶ 117, and plaintiffs James Carlson and

William Costello originally purchased coverage in 1989 and also have maintained coverage since then, id. ¶ 118. The Continental policies at issue all contain the following language: “We cannot change the Insured’s premiums because of age or health. We can, however, change the Insured’s premiums based on his or her premium class, but only if We change the premiums for all other Insureds in the same premium class.” [132-4] at 50; see also [88] ¶¶ 323–24.3 The parties agree that the term “premium class” is not

defined in the policies. [163] at 7; [160] at 1. In 2015, Continental began raising premium rates on the plaintiffs’ long-term care policies. [88] ¶¶ 16–17. Rate increases must be approved by state insurance regulators, and Continental sought increased rates unevenly on a state-by-state

3 The Court uses the blue CM/ECF pagination for this exhibit. basis. Id. For example, Continental sought to increase rates by 15% in Maryland but 95.5% in Illinois. Id. ¶ 283. The subsequent variations in rate increases were significant: some states saw rates more than double, while others saw no increases

at all. Id. ¶¶ 284–85. According to plaintiffs, in addition to raising premium costs, these rate increases were intended to and resulted in Continental customers reducing or dropping their coverage, long after they had begun paying their premiums. [163] at 11. Plaintiffs describe this consequence as a “shock lapse” that Continental specifically intended. Id. As a result of these rate increases, plaintiffs filed five putative class actions against Continental. See supra note 1. These cases, now consolidated, share a core

theory: that the undefined term “premium class” in the insurance agreements refers to a nation-wide class of insured that “does not contemplate state-to-state variations in premium increases,” [163] at 7, and that by pursuing such uneven increases Continental has engaged in breach of contract and fraudulent concealment, [87] at 78–80. Plaintiffs seek certification of the following classes under Federal Rule of Civil Procedure 23:

Declaratory and Injunctive Relief Class: All persons insured under a Continental Casualty Company GLTC2 group long-term care insurance policy that was in force at the time CNA issued its first rate-increase notification letter covering that group policy.

Damages Class: All persons insured under a Continental Casualty Company GLTC2 group long-term care insurance policy that were subjected to a rate increase.

Reinstatement Class: All individuals who are or were insured under a Continental Casualty Company GLTC2 group long-term care insurance policy who have surrendered, reduced and/or dropped benefits and/or coverage at any point after CNA issued the initial rate-increase notification letter covering that group policy.

[163] at 16. And “in the event Court declines to certify a product-wide fraud class,” plaintiffs seek to certify six, state-specific “Fraudulent Concealment Subclasses within the damages class, consisting of class members who at the time their certificates were issued resided in the states of Illinois, California, Florida, Connecticut, Washington, and Arizona.” Id. II. Analysis Plaintiffs “bear[] the burden of demonstrating that certification is proper by a preponderance of the evidence.” Bell v. PNC Bank, Nat’l Ass’n, 800 F.3d 360, 373 (7th Cir. 2015). In determining whether they have met this burden, the Court only evaluates evidence to decide whether certification is proper. Messner v. Northshore Univ. HealthSystem, 669 F.3d 802, 811 (7th Cir. 2012). Class-certification proceedings are not a “dress rehearsal for the trial on the merits.” Id.

Under Rule 23(a) of the Federal Rules of Civil Procedure, plaintiffs must satisfy the following prerequisites for bringing a class action in federal court: (1) numerosity, (2) commonality, (3) typicality, and (4) adequacy of representation. Fed. R. Civ. P. 23(a). The Seventh Circuit also has “long recognized an implicit requirement under Rule 23 that a class must be defined clearly and that membership be defined by objective criteria rather than by, for example, a class member’s state of mind.” Mullins v. Direct Digital, LLC, 795 F.3d 654, 657 (7th Cir. 2015). Plaintiffs

who establish all of those elements must then show they qualify for a particular type of class action under Rule 23(b). A. Rule 23(a) Continental concedes that plaintiffs satisfy the numerosity requirement, [160] at 28 and does not dispute that the proposed classes—which are defined clearly by the objective criteria of when and where people were insured—meets the implicit

ascertainability requirement. But even if plaintiffs satisfied the remaining typicality and adequacy-of-representation requirements, they fail to satisfy the commonality requirement.

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