Rajabi v. Sedgwick Claims Management Services, Inc.

CourtCourt of Appeals for the Tenth Circuit
DecidedJanuary 14, 2026
Docket24-1326
StatusUnpublished

This text of Rajabi v. Sedgwick Claims Management Services, Inc. (Rajabi v. Sedgwick Claims Management Services, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Rajabi v. Sedgwick Claims Management Services, Inc., (10th Cir. 2026).

Opinion

Appellate Case: 24-1326 Document: 59-1 Date Filed: 01/14/2026 FILED Page: 1 United States Court of Appeals Tenth Circuit UNITED STATES COURT OF APPEALS January 14, 2026 FOR THE TENTH CIRCUIT Christopher M. Wolpert _________________________________ Clerk of Court

CYRUS RAJABI,

Plaintiff - Appellant,

v. No. 24-1326 (D.C. No. 1:21-CV-00422-GPG-JPO) SEDGWICK CLAIMS MANAGEMENT (D. Colo.) SERVICES, INC.; TRISTAR GROUP, d/b/a Tristar Managed Care, d/b/a Tristar Risk Management,

Defendants - Appellees. _________________________________

ORDER AND JUDGMENT * _________________________________

Before MATHESON, EBEL, and EID, Circuit Judges. _________________________________

Cyrus Rajabi sued Sedgwick Claims Management Services, Inc. and Tristar

Group (collectively, the “Claims Administrators”) for breach of the duty of good

faith and fair dealing under Colorado law. The district court entered summary

* After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 24-1326 Document: 59-1 Date Filed: 01/14/2026 Page: 2

judgment against Mr. Rajabi, concluding he lacked sufficient evidence to prove his

claim.

On appeal, Mr. Rajabi argues the court (1) erred in granting summary

judgment and (2) abused its discretion in denying him a stay of the litigation and an

extension of discovery deadlines. Exercising jurisdiction under 28 U.S.C. § 1291, we

affirm.

I. BACKGROUND

A. Factual History 1

On April 23, 2017, Mr. Rajabi—a volunteer firefighter—was injured during a

training exercise with the Arvada Fire Protection District. “He dislocated three

fingers, tore ligaments and a tendon, and sustained an avulsion fracture and nerve

damage.” Rajabi v. Sedgwick Claims Mgmt. Servs., Inc., No. 21-cv-422, 2024 WL

3835697, at *1 (D. Colo. July 12, 2024). Mr. Rajabi reported the incident to his

employer, Arvada Fire, which “filed a claim with its Workers’ Compensation

Carrier.” App., Vol. I at 71. “Tristar—a third-party claims administrator—handled

[Mr. Rajabi’s] claim from the date initially submitted to July 2020,” when Sedgwick

took over claims-handling duties. Rajabi, 2024 WL 3835697, at *1.

“Because this case arises from an appeal of summary judgment, we present the 1

following factual background in the light most favorable to [Mr. Rajabi] as the non-moving party, unless contradicted by the record.” Litzsinger v. Adams Cnty. Coroner’s Off., 25 F.4th 1280, 1284 (10th Cir. 2022).

2 Appellate Case: 24-1326 Document: 59-1 Date Filed: 01/14/2026 Page: 3

Following the incident, Mr. Rajabi was diagnosed with Complex Regional

Pain Syndrome (“CPRS”)—chronic pain that develops after an injury or other

traumatic event. Id. From 2017 to 2022, he received extensive medical treatment.

His treating physicians sought authorization from the Claims Administrators for

coverage of Mr. Rajabi’s medical treatments. Relying on reports from their

consulting physicians, the Claims Administrators denied authorization when the

reports concluded that treatment was not medically reasonable and necessary or

causally related to the April 23, 2017 injury.

B. Legal Background

Colorado law requires an insurer “to treat an insured with good faith.”

Sandoval v. Unum Life Ins. Co. of Am., 952 F.3d 1233, 1236 (10th Cir. 2020); see

Am. Family Mut. Ins. Co. v. Allen, 102 P.3d 333, 342 (Colo. 2004) (en banc). An

insured may sue for breach of this duty. See Peden v. State Farm Mutual Auto. Ins.

Co., 841 F.3d 887, 890 (10th Cir. 2016). To prevail, “the insured must prove that the

insurer (1) acted ‘unreasonably under the circumstances’ and (2) ‘knowingly or

recklessly disregarded the validity of the insured’s claim.’” Id. (quoting Goodson v.

Am. Standard Ins. Co. of Wis., 89 P.3d 409, 415 (Colo. 2004) (en banc)). “The

reasonableness of the insurer’s conduct must be determined objectively, based on

proof of industry standards,” which “often require[s]” the “aid of expert witnesses.”

Goodson, 89 P.3d at 415.

In making a reasonableness determination, courts may consider a

fairly-debatable standard. It provides that “[i]f a reasonable person would find that

3 Appellate Case: 24-1326 Document: 59-1 Date Filed: 01/14/2026 Page: 4

the insurer’s justification for denying or delaying payment of a claim was ‘fairly

debatable’ (i.e., if reasonable minds could disagree as to the coverage-determining

facts or law), then this weighs against a finding that the insurer acted unreasonably.”

Sanderson v. Am. Fam. Mut. Ins. Co., 251 P.3d 1213, 1217 (Colo. App. 2010). But

even though “fair debatability” may help the insurer, it is not “outcome

determinative.” Id. at 1218. The insurer still “must exercise reasonable care and

good faith” in handling the claim. Id. (quotations omitted). “[A]n insurer will be

found to have acted in bad faith only if it has intentionally denied, failed to process,

or failed to pay a claim without a reasonable basis.” Zolman v. Pinnacol Assur.,

261 P.3d 490, 497 (Colo. App. 2011). 2

C. Procedural History

On October 23, 2020, Mr. Rajabi filed his complaint in state court. The

Claims Administrators removed the case to federal court based on diversity

jurisdiction. Rajabi, 2024 WL 3835697, at *1.

The Complaint

Mr. Rajabi’s complaint alleged that the Claims Administrators “wrongfully

delayed and/or failed to pay for Mr. Rajabi’s medical treatment . . . and/or denied

medical treatment for Mr. Rajabi.” App., Vol. I at 23. He alleged that, “[i]nstead of

relying on [Mr. Rajabi’s] treating physicians,” the Claims Administrators “would

2 Because the district court concluded that Mr. Rajabi failed to put forth “any competent summary judgment evidence” supporting his claim, it did not analyze the fairly-debatable standard. Rajabi, 2024 WL 3835697, at *4.

4 Appellate Case: 24-1326 Document: 59-1 Date Filed: 01/14/2026 Page: 5

default to . . . ‘independent’ medical exams or record reviews performed by

physicians known by [the Claims Administrators] to provide reports favorable to

[their] position in contested workers’ compensation claims.” Id.

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