Court of Appeals Affirms Dismissal of Bad Faith Case
In Saltern v. HNI Corp., No. 13-1193 (Iowa App. Aug. 13, 2014), the parties agreed to settle the case on an agreement for settlement basis, with defendants agreeing to pay penalty benefits for the delay in paying benefits. After the AGFS was filed, claimant filed a bad faith claim and filed a motion for partial summary judgment urging the court to find that there was no reasonable basis to deny and delay benefits. Defendants filed a cross motion for summary judgment, urging dismissal. The district court denied claimant's motion and granted defendants' motion.
Defendants argued that the facts in the workers' compensation case were such that there was a question of whether claimant slipped on ice in the parking lot, or whether the fall was idiopathic in nature. Claimant argued that defendants' action of agreeing to payment of penalty demonstrated that there was no reasonable basis for its action in denying and delaying payment of benefits. Claimant argued that the payment of penalty judicially estopped defendants from asserting they had a reasonable basis to deny the claim. The district court did not address this claim and ruled against claimant.
Claimant filed a motion for rehearing under IRCP 1.904(2) but did not receive a ruling on that motion prior to filing her appeal. The court of appeals concludes that because of this, claimant divested the district court of jurisdction under IBP, Inc. v. Al-Gharib, 604 N.W.2d 621, 628 (Iowa 2008). Thus, the court did not consider claimant's judicial estoppel argument. The court went on to affirm the district court's ruling sustaining defendants' motion for summary judgment. The court found that the claim was fairly debatable because there was testimony that there was no ice on the ground and that defendants had a objectively and subjectively reasonable basis for denial of the claim. The court found there was a reasonable basis for denying benefits and the decision of the district court was affirmed.
Defendants argued that the facts in the workers' compensation case were such that there was a question of whether claimant slipped on ice in the parking lot, or whether the fall was idiopathic in nature. Claimant argued that defendants' action of agreeing to payment of penalty demonstrated that there was no reasonable basis for its action in denying and delaying payment of benefits. Claimant argued that the payment of penalty judicially estopped defendants from asserting they had a reasonable basis to deny the claim. The district court did not address this claim and ruled against claimant.
Claimant filed a motion for rehearing under IRCP 1.904(2) but did not receive a ruling on that motion prior to filing her appeal. The court of appeals concludes that because of this, claimant divested the district court of jurisdction under IBP, Inc. v. Al-Gharib, 604 N.W.2d 621, 628 (Iowa 2008). Thus, the court did not consider claimant's judicial estoppel argument. The court went on to affirm the district court's ruling sustaining defendants' motion for summary judgment. The court found that the claim was fairly debatable because there was testimony that there was no ice on the ground and that defendants had a objectively and subjectively reasonable basis for denial of the claim. The court found there was a reasonable basis for denying benefits and the decision of the district court was affirmed.
Comments
Post a Comment