Smith v. Prudential Insurance Company of America, No. 23-1168 (1st Cir. 2023)
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Brian Smith, a Rhode Island resident, sued Prudential Insurance Company of America for breach of fiduciary duty after the company terminated his long-term disability benefits under an insurance policy. The policy stated a three-year limitations period to file a lawsuit, which began on the date Smith was required to submit proof of his disability, not on the date Prudential allegedly breached the policy by stopping payment. Consequently, by the time Smith filed his lawsuit, the limitations period had expired. Smith appealed to the United States Court of Appeals for the First Circuit after the United States District Court for the District of Rhode Island granted summary judgment in favor of Prudential on the grounds that Smith's lawsuit was filed too late.
Smith argued that enforcing the limitations scheme would violate Rhode Island public policy. While the Court of Appeals found compelling reasons to believe that the limitations scheme might indeed contravene Rhode Island public policy, they also recognized that reversing and remanding on that ground would potentially expand Rhode Island law. Consequently, the Court of Appeals decided to certify the public policy question to the Rhode Island Supreme Court. The certified question is whether, in light of specific state laws and Rhode Island public policy, Rhode Island would enforce the limitations scheme in this case to bar Smith's lawsuit against Prudential.
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