Cherri Walker v. Life Insurance Company of North America, No. 21-12493 (11th Cir. 2023)
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Life Insurance Company of North America (“LINA”) made multiple determinations that Plaintiff did not qualify for disability benefits under her long-term disability insurance policy and her life insurance policy. Plaintiff sued LINA for breach of contract and bad-faith failure to provide insurance benefits. The district court granted summary judgment for LINA on Plaintiff’s bad-faith claim based on the multiple medical opinions that supported LINA’s determinations. The district court held that, under Alabama law, Plaintiff could not recover mental anguish damages for her breach of contract claim and excluded evidence of such damages. Finally, following a jury verdict in Plaintiff’s favor on the breach of contract claim related to the long-term disability insurance policy, the district court determined that Plaintiff was entitled to simple pre-judgment interest at a rate of 1.5 percent under the policy and simple post-judgment interest at a rate of 0.08 percent pursuant to 28 U.S.C. Section 1961. In determining that the long-term disability insurance policy provided for simple rather than compound interest, the district court struck a document produced by Plaintiff because it was not properly authenticated. On appeal, Plaintiff argued that the district court erred at each of these steps.
The Eleventh Circuit affirmed. The court held that the evidence establishes that LINA had an arguable reason for determining that Plaintiff did not qualify for disability benefits under the disability policy. Further, the court wrote that the Supreme Court of Alabama has made clear that mental anguish damages are unavailable for breach of contract claims related to long-term disability insurance policies.
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