Blue v. Hartford Life & Accident Insurance
698 F.3d 587
7th Cir.2012Background
- Blue was insured by Hartford under a long-term disability plan; Hartford mistakenly applied the any-occupation standard rather than the own-occupation standard, which had been retroactively amended in 2002.
- Hartford terminated Blue’s LTD benefits in 2008 under the wrong standard and denied his appeal; Hartford eventually reinstated benefits with backpay after discovering the error in 2011.
- Blue filed suit in Wisconsin state court asserting breach of contract and bad-faith denial of benefits; Hartford removed to district court.
- Blue moved for summary judgment; Hartford admitted liability and reinstated benefits but sought summary judgment on the bad-faith claim.
- Blue’s responses were delayed due to personal and health issues; the district court denied extensions and ruled summary judgment for Hartford on both the bad-faith and mootness/privacy of the contract claim.
- The Seventh Circuit affirmed, holding no abuse of discretion in denying extensions and granting summary judgment for Hartford on both bad faith and contract claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court abused discretion denying second extension | Blue | Hartford | No abuse of discretion |
| Whether summary judgment on bad faith was proper | Blue | Hartford | Yes, Hartford did not act in bad faith |
| Whether Hartford’s conduct violated bad-faith standard | Blue | Hartford | Yes, no material factual dispute of recklessness or knowledge |
| Whether breach-of-contract claim was moot after reinstatement | Blue | Hartford | Yes, moot to the extent of relief already granted |
| Whether Rule 59(e) motion was properly denied | Blue | Hartford | Yes, no manifest error or new evidence |
Key Cases Cited
- Jovanovic v. In-Sink-Erator Div. of Emerson Elec. Co., 201 F.3d 894 (7th Cir. 2000) (abuse of discretion in denying extension of time for responsive pleadings)
- Gonzalez v. Ingersoll Milling Mach. Co., 133 F.3d 1025 (7th Cir. 1998) (trial-management discretion in extensions and scheduling)
- Spears v. City of Indianapolis, 74 F.3d 153 (7th Cir. 1996) (last-minute discovery delays and need to keep litigation moving)
- Deere & Co. v. Ohio Gear, 462 F.3d 701 (7th Cir. 2006) (summary judgment and discovery related rulings; Rule 56(f) considerations)
- Yancick v. Hanna Steel Corp., 653 F.3d 532 (7th Cir. 2011) (reaffirming need to timely seek relief for discovery issues)
- Anderson v. Continental Ins. Co., 271 N.W.2d 368 (Wis. 1978) (two-part bad-faith test: absence of reasonable basis and knowledge or reckless disregard)
- Brethorst v. Allstate Prop. & Cas. Ins. Co., 798 N.W.2d 467 (Wis. 2011) (reckless disregard element; knowledge of lack of basis)
- Pakovich v. Verizon LTD Plan, 653 F.3d 488 (7th Cir. 2011) (mootness when relief requested has been fully provided)