Hartford Accident and Indemnity Company v. Lin, No. 22-2776 (7th Cir. 2024)
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This case involves a dispute between Zhen Feng Lin, a food delivery driver who was severely injured in a car accident, and his employer's insurance company, Hartford Accident and Indemnity Company. After the accident, Lin received a settlement from the at-fault driver's insurance company, and workers' compensation benefits from his employer's insurance carrier, Hartford Fire Insurance Company. Lin later sought additional recovery under his employer's underinsured motorist policy with Hartford Accident.
The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision that Lin and Hartford Accident had not entered into a "settlement agreement" as defined by the insurance policy. As a result, the court ruled that the policy limits should be reduced by the amount Lin received in workers' compensation benefits. The court also agreed with the district court that Lin should be credited for the amount he paid to settle the workers' compensation lien.
Additionally, the court affirmed the district court's dismissal of Lin's counterclaims for bad faith and breach of contract. The court found no plausible claim supporting the argument that Hartford Accident unreasonably delayed settling Lin's claim. Lin's request for statutory penalties for Hartford Accident's purported delay in handling his claim was also denied.
Finally, the court denied both parties' motions for sanctions. Lin's appeal was deemed frivolous in part, but the court exercised its discretion not to impose sanctions.
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