Armisted v. State Farm Mutual Automobile Insurance, 675 F.3d 989

Background

Plaintiffs are six catastrophically injured individuals seeking no-fault benefits for at-home attendant care.
State Farm initially paid benefits at the settlements’ rates, then reduced payments based on market surveys.
State Farm required documentation to justify higher rates; plaintiffs refused to provide detailed care documentation.
State Farm suspended some benefits after failing to verify ongoing attendant care; discovery disputes arose, leading to sanctions against State Farm.
After a 20-day trial, the jury awarded no extra benefits to plaintiffs; district court denied new-trial motion and partially granted attorney-fee relief.
The district court stayed sanctions pending appeal; plaintiffs appeal merits, while State Farm cross-appeals on sanctions and fees.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the denial of a new trial was an abuse of discretion	Armisted contends the verdict was against the weight of the evidence.	State Farm argues the verdict was supported by the evidence and properly instructed.	No abuse; verdict within the zone of reasonable determinations; no new trial.
Whether incurrence of no-fault expenses was properly proven	Armisted asserts documented proof is not strictly required and that family-provided care is compensable.	State Farm argues that incurred expenses require detailed proof and documentation.	Jurors could reasonably conclude lack of documentation undermined incurrence; verdict sustained.
Whether the verdict form and instructions correctly framed the incurred-expense issue	Armisted contends the form misled; evidence of incurred expenses was present.	State Farm contends instructions made clear the incurred-expense question and deductions from prior payments were proper.	Instructions and verdict form properly guided the jury; no reversible error.
Whether the district court erred in denying attorney-fee relief on Parks/Stewart claims	N/A	State Farm claims Parks/Stewart claims were fraudulent and fees should be awarded.	District court’s factual findings regarding Parks/Stewart were not clearly erroneous; no abuse of discretion in denying fees.
Whether the sanctions on discovery were reviewable on appeal	Appeal challenges district court’s discovery sanctions.	State Farm argues sanctions are final and reviewable.	Appeal dismissed for lack of jurisdiction on sanctions; merits remain reviewable.

Key Cases Cited

Budinich v. Becton Dickinson & Co., 486 U.S. 196 (1988) (attorney-fee issues may be final independently of merits)
Turnbull v. Wilcken, 893 F.2d 256 (10th Cir.1990) (merits finality allows review despite unresolved sanctions)
Booth v. Auto-Owners Ins. Co., 569 N.W.2d 903 (Mich. App. 1997) (documentation not required for existence of incurred expenses; jury credibility)
Moghis v. Citizens Ins. Co. of Am., 466 N.W.2d 290 (Mich. App. 1990) (extent of aid proven by testimony; documentation supportive but not sole determinant)
Santos v. Posadas De Puerto Rico Assocs., Inc., 452 F.3d 59 (1st Cir. 2006) (examine verdicts with accompanying instructions)
Williams v. AAA Mich., 646 N.W.2d 476 (Mich. App. 2002) (burden to prove incurred expenses by preponderance)
Van Marter v. Am. Fid. Fire Ins. Co., 318 N.W.2d 679 (Mich. App. 1982) (care need not be provided by trained medical personnel)