Keeping
the Faith in Suspicious First Party Claims
by: Anna Lisa Awiszus
Law Office of Patrica Tweedy
We’ve
all heard the buzzwords of “good faith” and “fair dealing”,
but where do they come from and how do they apply to investigations
of suspicious first party claims? The duty of good faith
and fair dealing is implicit in every insurance contract.
In the context of insurance contracts, the insurer is obligated
to act fairly and in good faith in meeting its contractual
obligations.
These duties have their roots in
general contract law. General contract law usually limits
damages of the injured party to actual contract damages.
However, California has carved out an exception when an
insurer violates its contractual duties. Citing a variety
of public policy reasons, courts have held that insurers
can be held liable in tort, as well as contract. Gruenberg
v. Aetna Insurance Company (1973) 9 Cal. 3d 566, 575. Thus,
a “bad faith” claim encompasses breach of contract issues,
as well as tort remedies for breaches of the implied duties.
What constitutes “bad faith”? You
may be surprised to learn that it is not defined as malicious
or immoral misconduct. It simply means that an insurer acted
“deliberately”. Neal v. Farmers Insurance Exchange (1978)
21 Cal. 3d 910, 921. Clear as mud, right? Isn’t every action
we take, whether misguided or not, deliberate in some way?
The courts have tried to clear this up with case law: The
insured, in a bad faith claim, must show that the insurer
failed or refused to live up to contract responsibilities,
consciously and deliberately, unfairly frustrated the purpose
of the contract, failed to meet the reasonable expectations
of the insured, and deprived him or her of the benefits
of the contract. Careau & Co. v. Security Pacific Business
Credit, Inc. (1990) 222 Cal. App. 3d, 1371, 1395. A cause
of action may arise from an unreasonable delay in the payment
of benefits.
Ok, so much for the law. What does
this really mean in terms of claims handling of a suspicious
loss? Does the spectre of bad faith prevent an insurer from
conducting a thorough investigation? Simply put, no. Let’s
start at the beginning, when the insurer is first notified
of the loss. This is a critical stage in the claim, for
the initial contact between the insured and insurer will
set the tone for the entire investigative process. An insured
will expect prompt attention to his or her loss, directly
from the insurer. Outside adjusting services can be very
responsive and are invaluable for attending to insureds
located away from the adjuster. However, it is important
that the insurer also promptly contact the insured, introducing
the adjuster on the claim and answering questions the insured
may have about the investigation or policy benefits.
An insured should not be given
the impression he or she is being given the runaround, or
avoided by the insurer. The key to resolving a suspicious
claim is a prompt and thorough investigation. A prompt and
thorough investigation will minimize benefits paid out on
a fraudulent claim and protect an insured who has a legitimate
claim. Remember, it is important to investigate exonerating
information just as zealously as suspicious leads. The insurer
should immediately provide the insured with a sworn statement
in proof of loss form and contents/personal property inventory
forms. The insured should also be provided with pertinent
excerpts from the policy, setting forth the insured’s duties
to complete the forms and submit them to the insurer within
the requisite time, usually sixty days. The insured should
be cautioned that misrepresentations can be grounds for
denial of policy benefits. A reservation of rights letter
should be sent to the insured if there are unresolved coverage
issues, such as a suspicious loss or a loss potentially
not covered under the policy.
As soon as possible, recorded statements
should be obtained from the insureds. Coverage issues requiring
counsel should be forwarded to counsel when they arise,
not after they have reached a critical mass stage. If the
insured requests information about his or her policy, it
should be forwarded without delay, with the applicable declarations
page, policy addendum’s and schedules. The insurer should
also review not only the policy, but all schedules, addendum’s
and changes that may have been made to the policy since
inception.
The insurer’s investigation of
the claim should begin promptly, and move along without
delay, regardless of whether the loss is suspicious or not.
It is not appropriate to wait for local authorities to complete
their investigations. This could result in liability for
failing to resolve the claim in a reasonable time frame,
even if benefits are ultimately paid.
In property losses involving theft,
vandalism or fire, photographs should be taken of the loss
premises, with particular attention to closets, storage
spaces or other relevant areas. Have the loss property inspected
as soon as possible to determine what remnants of furnishings,
clothing and electronic equipment are present. Hire a specialist
as to determine the cause and origin if the claim involves
fire loss. Instruct the insured to submit receipts or other
documents to support a claim for additional living expenses,
if applicable.
A great deal of information will
be provided by the insured, but what happens when the insured
does not cooperate as quickly or zealously as you would
like? Can you cease working on the claim until the insured
provides you with what you asked for? It is critical for
the insurer to understand that the insured’s failure to
timely respond to the insurer’s requests for information
or documents does not alleviate the insurer’s responsibilities
to investigate and resolve the claim in a reasonable time
frame. Generally, the burden is on the insurer to establish
that the insured’s failure to comply resulted in real prejudice
to the insurer, even if the insured has technically violated
a policy term. Simply put, an insurer cannot cease its investigation
or deny benefits if an insured’s conduct did not prejudice
the insurer. There are exceptions to this rule, including
an insured’s repeated an unreasonable failure to comply
with a policy term, like submitting to an examination under
oath.
The insurer should not underestimate
the wealth of information that an insured’s supporting documentation
contains. Insurers have uncovered fraudulent claims by carefully
reviewing receipts, warranties and other documents provided
by the insured. Dates and places of purchase or service
can be just as important as a receipt. For example, one
insurer recently resolved a suspicious theft claim based,
in part, on a computer repair invoice its insured submitted
to show the make and model of his computer, allegedly stolen
from his home. The invoice revealed that the “stolen” computer
was taken in for repairs after the date of loss! At the
subsequent examination under oath, the insured continued
to assert the loss, until the invoice date was pointed out
to him. He admitted, on the record, that he had lied. The
claim was denied on material misrepresentations made in
the pursuit of insurance benefits.
The investigative process should
also include a review of the insurance history of the insured.
For example, an insurer investigated the loss history of
an insured who claimed that several pieces of jewelry were
stolen from her home. The insured had previously purchased
additional insurance to cover the jewelry. A review of her
loss history obtained from former insurers revealed that
she had claimed virtually every item as stolen before her
current loss date. Additionally, she had informed the insurance
company that she canceled her previous policy because she
was unhappy with the rates and customer service. However,
the investigating insurer learned that her previous insurer
had canceled her policy two months prior, due to multiple
claims. The claim was, of course, ultimately denied.
Places of purchase can also provide
valuable clues as to the whereabouts of an insured during
key points in time. For example, if an insured claims he
or she was out of town on certain days, yet submits receipts
for local purchases, further investigation is warranted.
Also, vendors should be contacted if any receipt appears
suspicious. One insurance company resolved a suspicious
claim by contacting retailers whose name appeared on receipts
submitted by its insured. Printed invoices attributed to
a local furniture shop were found to be falsified by the
insured. The claim was denied for these material misrepresentations.
The duty of good faith and fair dealing requires the insurer
to conduct a prompt investigation of first party losses
and to pay policy benefits, if appropriate, in a reasonable
time frame. The duty of good faith is met, not violated,
by a prompt and thorough investigation. To avoid bad faith
litigation, act promptly and fairly to the appropriate resolution
of each claim.
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