Bates v. Superior Court

Gloria Bates was a resident of Michigan in 1975 when she was injured in an automobile accident in Illinois and made claims for her medical expenses with Nationwide, her insurer, through its Michigan office. Nationwide provided Gloria benefits for her accident-related medical treatment. Gloria later moved to Arizona, and Nationwide continued to pay her medical bills until her Michigan agent retired in 1985 and it transferred her claim file to its home office in Ohio and Gloria was asked to be reevaluated. A doctor in Phoenix determined that Gloria’s condition no longer required medical treatment, so Nationwide’s Ohio claims staff quit paying Gloria’s medical bills. Gloria sued Nationwide in Arizona for breach of contract and bad-faith insurance practices after her requests for reconsideration were denied. Michigan did not recognize a cause of action for bad-faith insurance practices, but Arizona and Ohio did. Nationwide argued that Michigan law should control because it was the state with the most significant contacts to the claim. Gloria argued that Ohio and Arizona had the most significant contacts with the claim. The trial court concluded that Michigan had the most significant contacts and granted partial summary judgment for Nationwide. Gloria’s motion for reconsideration was denied, and she appealed. After the court of appeals denied jurisdiction, Gloria appealed to the Arizona Supreme Court.