Wiley v. Unum Life Insurance Company of America
- William Orrick
- 3:19-cv-02756
- U.S. District Court · Northern District of California
- 2
In Wiley v. Unum, Judge Orrick required a proximate-cause jury instruction, rejecting Wiley’s proposed any-contribution standard for lifetime coverage.
Darrell Wiley and Unum Life Insurance Company of America, whose upcoming trial would use the court’s proximate-cause jury instruction.
What happened
In Wiley v. Unum Life Insurance Company of America, Darrell Wiley proposed a jury instruction about interpreting the insurance contract. Unum objected, and Judge William Orrick explained that contract interpretation is decided by the court, not the jury.
The parties disagreed about what connection an injury must have to a disability for lifetime coverage. Unum accepted a proximate-cause test, while Wiley argued that any contribution by the injury was enough. The court rejected both a sole-cause standard and Wiley’s broader any-contribution standard.
Judge William Orrick ordered that the jury instruction would use proximate cause, described through a “substantial factor” formulation. The order addressed the disputed instruction and did not decide the case’s ultimate outcome.
The detailed version
- Wiley v. Unum Life Insurance Company of America · No. 3:19-cv-02756
- William Orrick
- May 18, 2022
Background
Darrell Wiley proposed a jury instruction concerning contract interpretation in his dispute with Unum Life Insurance Company of America. Unum objected. The court concluded that the proposed instruction was improper because interpreting a contract is a legal question for the court rather than the jury.
The court separately proposed a causation instruction addressing the parties’ principal disagreement and invited briefing. Unum did not object to using a proximate-cause test. Wiley argued that any contribution by the injury to his disability should be sufficient to obtain lifetime coverage.
Court’s Analysis
The court rejected the idea that the injury had to be the sole cause of the disability. It relied on policy language addressing disabilities resulting from concurrent causes and concluded that the policy contemplated coverage when a disability had multiple causes.
The court also rejected Wiley’s any-contribution standard. Although the policy did not expressly state a causation standard, the court said California’s Insurance Code and related case law generally use proximate cause rather than a merely remote cause. The court further reasoned that interpreting the policy to impose liability for remote contributing factors would produce unusual results and was not a reasonable interpretation of the contract.
The court stated that an “excluded risk” instruction was not appropriate because that type of instruction addresses the predominant cause, while the court concluded that any proximate cause—not only the predominant cause—would be sufficient. The court also noted that the policy used both “accident” and “injury” and said the parties could discuss whether changing that wording mattered at trial.
Ruling
Judge William Orrick ordered that he would use the proposed jury instruction, with or without Unum’s suggested wording change, based on California Civil Jury Instruction No. 2306 and adding a “substantial factor” formulation to mean proximate cause. This order resolved the disputed jury-instruction issue but did not state the ultimate outcome of Wiley’s claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.