Kathleen O'Keeffe v. Continental Casualty Co.

CourtCourt of Appeals for the Sixth Circuit
DecidedAugust 27, 2020
Docket20-3014
StatusUnpublished

This text of Kathleen O'Keeffe v. Continental Casualty Co. (Kathleen O'Keeffe v. Continental Casualty Co.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kathleen O'Keeffe v. Continental Casualty Co., (6th Cir. 2020).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 20a0507n.06

No. 20-3014

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Aug 27, 2020 KATHLEEN O’KEEFFE, ) DEBORAH S. HUNT, Clerk ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE CONTINENTAL CASUALTY COMPANY, ) NORTHERN DISTRICT OF ) OHIO Defendant-Appellee. ) ) )

BEFORE: CLAY, WHITE, and READLER, Circuit Judges.

CHAD A. READLER, Circuit Judge. A decade ago, policyholders sued Continental

Casualty Company (CNA) over its interpretation of certain long-term care policies. A settlement

resulted in CNA agreeing to, among other things, offer a new, alternative benefit to policyholders.

Today’s case challenges the parameters of that alternative benefit. Agreeing with the district court

that CNA’s interpretation is correct, we AFFIRM the judgment below.

BACKGROUND

The policy. Prior to her death, Vivian O’Connell was insured under a long-term care policy

issued by CNA. The policy defrayed the cost of a policyholder’s medical needs later in life by

paying a daily “Long-Term Care Facility Benefit” (LTCF Benefit) for a “benefit period” chosen

by the policyholder (in this case, six years). In addition to the benefit period limitation, the LTCF

Benefit was also subject to a daily reimbursement limit (in this case, $60 per day). Further, the

LTCF Benefit could be utilized only at facilities meeting strict qualifications. No. 20-3014, O’Keeffe v. Continental Casualty Company

As an alternative to the LTCF Benefit, O’Connell’s policy also offered the possibility of

an “Alternative Plan of Care Benefit” (APC Benefit). Policyholders who “otherwise require[d] an

eligible confinement” could utilize this benefit upon consultation with and agreement from both

CNA and medical professionals. Should agreement over a suitable APC Benefit come to pass,

payments to the policyholder would be set by negotiation and subject to a “maximum dollar

benefit” that applied to “the total of all benefits” paid by the LTCF or APC Benefits. Examples in

the policy of potential APC Benefits included a wheelchair ramp, kitchen/bathroom modifications,

and Alzheimer’s care.

The Pavlov litigation. In 2009, CNA policyholders initiated a class action challenging

CNA’s standard for determining which long-term facilities qualify for LTCF Benefit coverage.

Pavlov v. Cont’l Cas. Co., No. 5:07CV02580, 2009 WL 10689011 (N.D. Ohio Oct. 7, 2009). The

policy required that a long-term care facility have “24 hours a day” nursing services to be eligible

for coverage. Id. at *1. The parties disputed whether that provision meant that a nurse had to be

“on-site” at all times.

The case settled. Id. at *16. As part of the settlement, CNA agreed that a facility would

so qualify if it had a nurse on-site for five hours a day, seven days a week. Id. at *2. For

policyholders in facilities that did not meet even that lower bar, the settlement agreement offered

a second option, the “Alternative Plan of Care (‘APC’) benefit or accommodation,” or settlement

APC benefit. For policyholders utilizing non-qualifying facilities, the settlement APC benefit

would pay the policyholder the greater of 25% of the daily LTCF Benefit limit or the actual daily

cost of the facility, capped by the lesser of the daily LTCF Benefit limit or the actual daily cost of

the facility.

2 No. 20-3014, O’Keeffe v. Continental Casualty Company

The Pavlov Agreement contained two other provisions relevant to this litigation. One was

a clause asserting that a breach of its provisions would be a breach of contract, not a violation of a

court order. A second clause stated that the “claims handling change” relating to the nurse

provision—itself exclusively part of the LTCF Benefit, and not the policy’s APC Benefit—“shall

not affect any other term of the policy.”

The current case. O’Connell received two years of LTCF Benefits before moving to a non-

qualifying facility. At the new facility, CNA provided her settlement APC benefits pursuant to

the Pavlov Agreement. CNA terminated the settlement APC payments after four years, asserting

that O’Connell had exhausted her collective six-year benefit period. O’Connell, however, believed

that the policy’s benefit period limitation applied only to LTCF Benefits, not her settlement APC

benefit. Claiming a violation of the Pavlov Agreement, O’Connell, through her daughter Kathleen

O’Keeffe, initiated a class action against CNA.

O’Connell brought three claims. The first was that CNA breached its Pavlov settlement

obligations. O’Connell argued that her settlement APC benefits were limited not by the six-year

benefit period, but instead by the “maximum dollar benefit” term in her policy. As that cap was

$131,400 ($60 per day, 365 days per year, 6 years), O’Connell asserted that CNA breached the

Pavlov Agreement by terminating O’Connell’s benefits before she had received $131,400 in

benefits. O’Connell’s second claim was that CNA’s conduct amounted to bad faith under Illinois

common law. Finally, O’Connell claimed entitlement to attorney’s fees under Illinois law.

The district court granted CNA’s motion to dismiss. Interpreting the Pavlov Agreement

and O’Connell’s policy, the district court held that the benefit period limitation applied to both

LTCF Benefits and the Pavlov Agreement APC benefits. Likewise, because the policy’s

maximum dollar benefit serves as a ceiling (but not a floor) on the sum of APC and LTCF Benefits,

3 No. 20-3014, O’Keeffe v. Continental Casualty Company

the district court rejected O’Connell’s argument that she was entitled to that full amount. And

having held that CNA did not breach the Pavlov Agreement, the district court dismissed

O’Connell’s remaining claims as well, which relied on the occurrence of a breach of contract.

O’Connell timely appealed.

ANALYSIS

I. At the crux of this appeal is the district court’s reading of the Pavlov Agreement together

with O’Connell’s original policy. We review the district court’s decision to grant a motion to

dismiss for failure to state a claim de novo. In re Omnicare, Inc. Sec. Litig., 769 F.3d 455, 469

(6th Cir. 2014). In undertaking that review, we accept O’Connell’s “allegations as true and

construe the complaint in [her] favor, but the complaint’s factual allegations must be enough to

raise a right to relief above the speculative level.” Id. (cleaned up).

As a preliminary matter, this case has the potential to raise thorny conflict-of-law

questions: the Pavlov Agreement has a choice-of-law clause that selects Illinois law, O’Connell

moved to a North Dakota facility during the relevant period, and her complaint was filed in Ohio.

As this case is before us on diversity jurisdiction, we would ordinarily apply Ohio’s conflict-of-

laws doctrine to determine whether Illinois or North Dakota contract law governs the dispute.

State Farm Mut. Auto. Ins. Co. v. Norcold, Inc., 849 F.3d 328, 331 (6th Cir. 2017) (applying the

conflict-of-law rules of the forum state to determine which substantive state law applies). But

here, the parties agree that whether the governing law is from North Dakota or Illinois, our

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Kathleen O'Keeffe v. Continental Casualty Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/kathleen-okeeffe-v-continental-casualty-co-ca6-2020.