Campa v. United of Omaha Life Insurance Company

Background

On May 27, 2025, the court denied both Plaintiff Corina Campa’s motion for summary judgment and Defendant United of Omaha Life Insurance Company’s cross-motion for summary judgment. United later sought reconsideration of that interlocutory ruling, meaning a ruling made before the case was finally resolved. Campa opposed the motion.

The dispute involves United’s rescission of a life-insurance policy issued for Campa’s son after his death. United’s position was that, if it had known the son was a smoker, it would either not have issued the policy or would have issued it at a different rate. United relied on one medical record describing him as a “current some day smoker.” The opinion states that other records were inconsistent: one indicated that he did not smoke, and another listed his smoking status as unknown.

Reconsideration standard

Under Northern District of California Civil Local Rule 7-9, a party may seek reconsideration based on a previously unknown material difference in fact or law, new material facts or a change in law, or the court’s manifest failure to consider material facts or dispositive legal arguments presented before judgment. A party may not simply reargue points already presented. The court also noted that reconsideration motions are generally disfavored.

Court’s analysis

United argued that the court had failed to properly consider its challenge to Campa’s bad-faith claim. According to United, if it had a reasonable basis for its position about the policy, it could not be liable for bad faith as a matter of law. The court rejected reconsideration because United’s argument assumed that the son was a smoker, while the medical records created a factual dispute about that issue.

The court identified additional disputed material facts, including what the medical records showed about the son’s smoking status; whether and how United assessed that status before issuing the policy; how United evaluated the records before issuing and later rescinding the policy; and whether United acted reasonably in its investigation and communications with Campa.

United also argued that the evidence could not support punitive damages because it did not meet the higher standard required for such damages. The court agreed that Campa would face that higher standard at trial, but concluded that the evidence concerning United’s investigation and rescission was not so clear and one-sided that Campa could not prove bad faith. The court stated that this factual dispute was for the jury, not for resolution through summary judgment.

Disposition

Judge Noél Wise concluded that United had not identified a basis for reconsidering the summary-judgment ruling and denied United’s motion for reconsideration. The opinion leaves in place the earlier ruling denying both sides’ motions for summary judgment; it does not decide the disputed factual questions in United’s favor.