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Egan v. Mutual of Omaha Insurance Company
Supreme Court of California
24 Cal. 3d 809, 169 Cal. Rptr. 691, 620 P.2d 141 (1979)
Egan (plaintiff) purchased disability insurance from Mutual of Omaha Insurance Company (Mutual) (defendant). Egan filed a claim for reimbursement under the policy. Mutual denied Egan’s claim because its claims manager for Egan’s policy deemed the claim fraudulent. Egan brought suit against Mutual for breach of the implied covenant of good faith and fair dealing. Testimony at trial indicated that Egan was no longer able to work, despite his good-faith efforts. Egan had offered to undergo a medical evaluation by a doctor of Mutual’s choosing, but Mutual declined the offer and did not order any medical evaluation before denying Egan’s claim. The trial court found in favor of Egan, holding that Mutual had not sufficiently investigated Egan’s claim before denying it. The trial court awarded compensatory and punitive damages. Mutual appealed.
Rule of Law
Holding and Reasoning (Mosk, J.)
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