Hamilton v. Northfield Insurance Company, 6:16-cv-00519

Plaintiff Billy Hamilton owned a commercial building insured by Northfield Insurance under policy #WS219672.
In December 2015 Hamilton claimed roof and interior damage; Northfield denied coverage and later declined to renew the policy.
Hamilton sued for breach of contract and for breach of the insurer’s duty of good faith and fair dealing (seeking actual and punitive damages).
Northfield moved for summary judgment; it contended plaintiff lacked evidence (relying on a motion to exclude plaintiff’s expert) that wind caused the leak and therefore no breach.
The court denied the motion to exclude the expert and found a genuine factual dispute on breach of contract, but granted summary judgment for Northfield on the bad-faith and punitive-damages claims because the insurer had a reasonable, good-faith basis to investigate and deny the claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Breach of contract — cause of loss (wind)	Hamilton says wind caused the roof leak and Northfield breached by denying coverage	Northfield says no evidence wind caused the leak; denial was reasonable without expert opinion	Denied summary judgment to Northfield on breach; genuine dispute of material fact exists (expert admissible)
Bad faith — unreasonable denial/delay	Hamilton contends Northfield’s denial and nonrenewal show bad faith and inadequate investigation	Northfield argues its inspections and reinspection by an independent engineer provided a reasonable basis to deny coverage	Summary judgment for Northfield; insurer had a reasonable, good-faith basis to contest coverage, at most negligence
Punitive damages	Hamilton seeks punitive damages tied to bad faith showing	Northfield argues punitive damages unavailable absent reckless, malicious, or grossly negligent conduct	Denied — punitive damages not supported because no genuine bad-faith issue; conduct did not rise to required level
Independence of engineer	Hamilton suggests the hired engineer was not independent and investigation was biased	Northfield maintains the engineer was independent; plaintiff produced insufficient proof of bias	Court found insufficient evidence to show lack of independence; this does not create a triable bad-faith issue

J.V. v. Albuquerque Public Schs., 813 F.3d 1289 (10th Cir. 2016) (summary-judgment standards and genuine-issue explanation)
Wright v. Experian Info. Sols., Inc., 805 F.3d 1232 (10th Cir. 2015) (viewing evidence in favor of nonmoving party on summary judgment)
Automax Hyundai S., L.L.C. v. Zurich Am. Ins. Co., 720 F.3d 798 (10th Cir. 2013) (choice-of-law/district-court application of state law in diversity cases)
BP Am., Inc. v. State Auto Prop. & Cas. Ins. Co., 148 P.3d 832 (Okla. 2005) (insurance policies are contracts; interpret plain language)
Digital Design Grp., Inc. v. Info. Builders, Inc., 24 P.3d 834 (Okla. 2001) (elements of breach-of-contract claim)
Max True Plastering Co. v. U.S. Fid. & Guar. Co., 912 P.2d 861 (Okla. 1996) (insured’s reasonable expectations when construing ambiguous policy language)
Mansur v. PFL Life Ins. Co., 589 F.3d 1315 (10th Cir. 2009) (insurance contracts construed in favor of insured when ambiguous)
Southern Hospitality, Inc. v. Zurich Am. Ins. Co., 393 F.3d 1137 (10th Cir. 2004) (elements and limits of insurer’s duty of good faith and fair dealing)
Willis v. Midland Risk Ins. Co., 42 F.3d 607 (10th Cir. 1994) (investigation must be reasonably appropriate under the circumstances)
Sloan v. State Farm Mut. Auto. Ins. Co., 360 F.3d 1220 (10th Cir. 2004) (standard for punitive damages in insurance bad-faith cases)