Hunt v. Golden Rule Insurance
2011 WL 1467783
1st Cir.2011Background
- Hunt, insured with Golden Rule since 1987, had a major medical benefits policy including a $1,000,000 lifetime maximum and a separate $10,000 limit for mental or nervous disorders.
- The Mental or Nervous Disorders Exclusion references the 'amount shown on page 3' and ties to the lifetime limit and to the policy data page which lists the $1,000,000 and $10,000 figures.
- Hunt incurred mental health treatment costs in 2005–2007 totaling over $125,000; Golden Rule paid $8,505 previously and later paid only $1,494.19, asserting the lifetime maximum had been met.
- Hunt filed suit in New Hampshire state court, removed to federal court, asserting ambiguity of the policy’s limits and unfair trade practices based on discrimination against mental health claims.
- The district court granted summary judgment for Golden Rule, holding no ambiguity in the $10,000 cap and rejecting the discrimination claim under NH Unfair Insurance Trade Practices Law.
- On appeal, the First Circuit reviews de novo the district court’s interpretation of state law and policy language.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ambiguity of 'total liability' reference | Hunt argues page 3's 'total liability' could mean $1,000,000 or $10,000. | Golden Rule contends the natural reading is the $10,000 Mental/Nervous Disorder Limit and not the $1,000,000 cap. | No ambiguity; the $10,000 limit applies. |
| Proper interpretation of the two limits on page 3 | If ambiguous, the higher $1,000,000 applies to mental health benefits. | Two lifetime limits are clear and non-temporal; both are lifetime limits and are not ambiguous. | Policy language unambiguously caps mental health benefits at $10,000 lifetime. |
| Private right of action under RSA 417:4 | Discrimination claim should proceed as an unfair trade practice action. | NH Chapter 417 requires commissioner involvement; private damages action is unavailable without commission findings. | Private damages action is not available; district court proper to dismiss the discrimination claim. |
| Declaratory relief vs. permissible remedies under RSA 491:22 | Request for declaratory judgment should not be barred by the private-right-of-action constraint. | Declaratory relief would effectively bypass statutory scheme and be empty without damages. | Declaratory judgment sought is not appropriate; the procedural posture remains governed by Chapter 417. |
| Effect of RSA 417:5-a | Section preserves other remedies beyond commissioner powers. | Section does not create an unfettered private right of action. | Section 5-a does not provide a private right of action for Hunt; remedies are governed by commissioner processes. |
Key Cases Cited
- Godbout v. Lloyd's Ins. Syndicates, 150 N.H.103 (N.H. 2003) (interpreting insurance policy language and plain meaning)
- Concord Gen. Mut. Ins. Co. v. Doe, 8 A.3d 154 (N.H. 2010) (insurance policy interpretation as a question of law)
- International Surplus Lines Ins. Co. v. Mfrs. & Merchants Mut. Ins. Co., 661 A.2d 1192 (N.H. 1995) (avoid surplus language and interpret literally)
- Bukuras v. Mueller Grp., LLC., 592 F.3d 255 (1st Cir. 2010) (predicting state court interpretation of statutory claims)
- Arouchon v. Whaland, 409 A.2d 1331 (N.H. 1979) (primary aim of insurance trade practices is regulatory, not redress of individual wrongs)
- Andrew Robinson Int'l, Inc. v. Hartford Fire Ins. Co., 547 F.3d 48 (1st Cir. 2008) (predicting state court outcomes; federal court deference to state law interpretations)