Cooke v. Jackson National Life Ins. Co.

Dist. Ct. erred in awarding plaintiff $42,825 in attorney fees as sanction for defendant prolonging litigation over whether defendant had wrongfully refused to pay plaintiff $191,000 in proceeds on life insurance policy. While Dist. Ct. based said award on Illinois statute (215 ILCS 5/155) because defendant had failed to attach full insurance policy in its response to plaintiff’s motion for judgment on pleadings under Rule 12(c), which, Dist. Ct. found, precluded it from resolving case at that stage of instant proceeding, Dist. Ct. could not base any sanction award on state law, since federal rules apply to penalize any unreasonable conduct in instant federal litigation. Also, federal Rules of Civil Procedure do not require defendant to attach documents in response to Rule 12(c) motions, and Ct. of Appeals rejected plaintiff’s contention that sanctions were appropriate under Rules 11, 26(g)(3) and 37(b)(2)(C), as well as 28 USC section 1927. Moreover, Dist. Ct. properly found that defendant did not act inappropriately by initially rejecting plaintiff’s claim to proceeds of life insurance policy.