Ottemann v. Knights of Columbus, No. 21-30138 (5th Cir. 2022)
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The Knights of Columbus (“the Order” or “the KCs”) offers insurance products to its members. To promote and sell these insurance products, the Order contracts with Field Agents (“FAs”) and General Agents (“GAs”). FAs promote and sell insurance products to prospective customers, and GAs recruit and oversee FAs within a specified territory. Plaintiff began selling insurance for the Order in 2006 as an FA. He worked in that capacity until he became a GA.
He brought suit against the KCs alleging breach of contract, breach of duty of good faith, and wage payment law violations. The district court dismissed each of the claims for failure to state a claim.
The Fifth Circuit partly disagreed and thus reversed in part and affirmed in part. The court reversed the district court’s holding that Plaintiff failed to state a claim upon relief which can be granted regarding a breach of contract in relation to Section 4 of the GA contract, Section 6 of the FA contracts to which he was a party, and Section 7(c) of Plaintiff’s original FA contract reversed the district court’s holding that Plaintiff has failed to state a claim for the breach of the duty of good faith and fair dealing in relation to the performance of Section 4 of the GA contract and Section 6 of the FA contracts. The court also reversed the district court’s holdings that Plaintiff failed to state a claim under both the Connecticut and Louisiana wage payment laws. The court affirmed the remainder of the district court’s judgment, including the dismissal of Plaintiff’s equitable claims.
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