Blue v. Hartford Life & Accident Ins. Co.

In action alleging that defendant breached insurance contract and denied in bad faith plaintiff’s claim for long-term disability benefits, Dist. Ct. did not err in granting defendant’s motion for summary judgment. Plaintiff’s contract claim was moot where defendant had previously paid plaintiff all benefits due under contract after agreeing with plaintiff that defendant had used wrong standard in initially denying plaintiff’s application for said benefits. Moreover, plaintiff failed to present sufficient evidence with respect to plaintiff’s bad-faith claim where: (1) Wisconsin law required demonstration of defendant’s knowledge or reckless disregard of lack of reasonable basis for denying claim; (2) plaintiff failed to show that defendant knew it was applying wrong standard at time it denied plaintiff’s claim; and (3) defendant’s use of wrong standard was mere honest mistake.