Paulson v. State Farm Mutual Automobile Insurance

867 F. Supp. 911, 94 Daily Journal DAR 15992, 1994 U.S. Dist. LEXIS 15881, 1994 WL 608487
CourtDistrict Court, C.D. California
DecidedOctober 27, 1994
DocketCV 94-2691 JSL
StatusPublished
Cited by14 cases

This text of 867 F. Supp. 911 (Paulson v. State Farm Mutual Automobile Insurance) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Paulson v. State Farm Mutual Automobile Insurance, 867 F. Supp. 911, 94 Daily Journal DAR 15992, 1994 U.S. Dist. LEXIS 15881, 1994 WL 608487 (C.D. Cal. 1994).

Opinion

OPINION

LETTS, District Judge.

Plaintiff Boyd Paulson (“Paulson”) has sued his automobile insurance carrier, State Farm Mutual Automobile Insurance Company (“State Farm”) for breach of contract, bad faith, intentional infliction of emotional distress, negligent infliction of emotional distress, and fraud arising out of State Farm’s initial refusal to cover Paulson for injuries he sustained in an automobile accident caused by the negligence of an underinsured motorist. State Farm initially denied coverage to Paulson based on medical records indicating that Paulson had recovered fully from his injuries and on the fact that Paulson had received already $21,740 from the negligent driver’s insurer and his employer in workers’ compensation. State Farm eventually paid Paulson the $8,260 that he originally had requested, the full value of his insurance policy and its entire contractual obligation. 1

State Farm moved for summary judgment under Federal Rule of Civil Procedure 56, arguing that Paulson cannot sustain any of the causes of action alleged in his complaint as a matter of law. Based on a review of the file, record and proceedings, and for the reasons stated below, this Court granted defendant State Farm’s motion for summary judgment. Judgment was entered on October 17, 1994.

The legal issues in this case are not novel and ordinarily would not merit a written opinion. This case, however, is a prime example of what Ninth Circuit Judge Kozinski has labelled the “tortification of contract law,” or the tendency of courts to treat a contract dispute as a tort, which creates incentives for plaintiffs to invest in tort causes of action. See Oki America, Inc. v. Microtech Int’l, Inc., 872 F.2d 312, 315-16 (9th Cir.1989) (Kozinski, J., concurring) (discussing the tort of bad-faith denial of the existence of a contract). All contracts, including insurance contracts, include in their initial calculus the estimated costs of performance. This allows insurance companies, who are in *914 the business of writing contracts to pay claims, to price their policies accurately to include these costs. Tort damages, on the other hand, depend on case-by-case jury determinations that often turn on nebulous standards, resulting in the inability of insurance companies to estimate and account for those costs in advance. Thus, an insurer like State Farm facing potential tort liability for a failure to pay an insured’s policy limits on demand is under great pressure to settle the lawsuit rather than to spend large amounts of money and time to litigate the case to an unpredictable result. The ability of an insured to create a tort lawsuit out of a good faith denial of insurance coverage creates settlement value for the plaintiff out of proportion to the merits of the underlying contract dispute.

In a case like this, where the insured has obtained the full measure of contract performance, courts should make a threshold determination of whether the undisputed facts support the existence of a tort cause of action. Cf. Cox v. Resilient Flooring Div. of Congoleum Corp., 638 F.Supp. 726, 731 (C.D.Cal.1986) (facts which do not give rise to contractual liability should not form the basis for liability in tort of breach of implied-in-fact promise to terminate employee only for good cause). A possible standard for this determination would be whether the plaintiff has alleged facts which would, if proved, so shock the conscience of the court that to provide no remedy would frustrate the clear ends of justice. Cf. id. at 738 (proposing such a standard). Certainly, an insurer may remain liable in tort if it unreasonably and in bad faith withholds payment of the claims of its insured. Gruenberg v. Aetna Ins. Co., 9 Cal.3d 666, 576, 108 Cal.Rptr. 480, 486, 510 P.2d 1032, 1038 (1973). Courts, however, must be able to address at the earliest possible stage the initial determination of whether, as a matter of law and based on the undisputed facts, the insurer’s actions are unreasonable and in bad faith.

The following sections will set forth in more detail the undisputed facts and the Court’s conclusions of law.

I. UNDISPUTED FACTS

On March 6, 1992, plaintiff Paulson was involved in an automobile accident caused by the negligence of an underinsured motorist. At the time of the accident, Paulson was driving a van owned by his employer, Pacific Bell, and was operating it in the scope of his employment as a service technician. As a result of the accident, Paulson sustained various bodily injuries, including a broken finger, minor lower back pain, and a cut on his forehead.

Paulson received a total payment of $21,-740 from the insurance company of the driver who caused the accident, Allstate Insurance Company (“Allstate”), and from his employer, Pacific Bell, in workers’ compensation benefits. 2

On or about September 11, 1992, six months after the accident, Paulson submitted an underinsured motorist claim under his policy with State Farm. The policy provided Paulson with bodily injury coverage of $30,-000 in the event he was injured in an automobile accident caused by the negligence of an uninsured or underinsured motorist. Paul-son presented a claim for $8,260, the difference between what he received from Allstate and Pacific Bell and the limits of his underin-sured motorist policy.

Paulson’s claim was assigned to State Farm claim representative Nancy Bennett on September 11, 1992. State Farm claim superintendent Peggy Ellis was assigned to supervise Ms. Bennett’s handling of the file. 3

*915 That day, Bennett reviewed Paulson’s claim file, which included looking at and evaluating medical bills, records, and reports that Paulson had submitted to State Farm in support of his claim. The records that Bennett reviewed revealed that Paulson’s primary accident-related injury was a fractured little finger on his nondominant (left) hand. Paulson had undergone surgery for this injury, followed by three weeks of rehabilitative therapy.

Paulson’s hand surgeon, Dr. Mitehel Sil-verman, M.D., wrote a series of reports detailing Paulson’s post-surgical recovery. These reports indicated that Paulson experienced rapid and consistent progress in the healing of his finger injury. In his final report, dated July 22, 1992, Dr. Silverman wrote that Paulson’s finger essentially was healed. Dr. Silverman reported his “opinion that Mr. Boyd Paulson has no permanent disability nor prophylactic work restrictions.” Dr. Silverman concluded that “with regard to the injury in question, no further medical treatment or hand therapy is warranted.” 4

Paulson also received rehabilitative physical therapy at the California Hand Center following his surgery. His records from the Center indicate that he received treatment there on nine occasions between April 1,1992 and April 22, 1992.

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867 F. Supp. 911, 94 Daily Journal DAR 15992, 1994 U.S. Dist. LEXIS 15881, 1994 WL 608487, Counsel Stack Legal Research, https://law.counselstack.com/opinion/paulson-v-state-farm-mutual-automobile-insurance-cacd-1994.