Cook v. State Farm General Insurance Company
- Maxine Chesney
- 3:21-cv-02458
- U.S. District Court · Northern District of California
- 3
In Cook v. State Farm General Insurance Company, Judge Chesney denied reconsideration and denied without prejudice leave to amend because plaintiffs had not proposed new pleading language.
The ruling affects the plaintiffs, who could not file a reconsideration motion and whose alternative request to amend was denied without prejudice, and State Farm General Insurance Company.
What happened
In Cook v. State Farm General Insurance Company, plaintiffs asked to seek reconsideration of an earlier order or, alternatively, to amend their complaint. The earlier order granted State Farm's motion to dismiss or strike parts of the complaint.
Plaintiffs argued that the court had overlooked their position that a proposed injunction would not require State Farm to pay policy benefits. The court said it had considered and rejected that argument because the requested injunction would require State Farm to determine the payment amounts plaintiffs and proposed class members were entitled to receive under their policies.
Judge Chesney denied leave to file a reconsideration motion. She denied the alternative request for leave to amend without prejudice because plaintiffs had not submitted a proposed amended complaint or stated the language of a proposed new claim.
The detailed version
- Cook v. State Farm General Insurance Company · No. 3:21-cv-02458
- Maxine Chesney
- June 2, 2022
Background
In an April 26, 2022 order, the court granted State Farm's motion to dismiss or strike portions of plaintiffs' Second Amended Complaint. The court concluded that plaintiffs' proposed injunction under California Business and Professions Code section 17200 would require State Farm to determine the policy-benefit amounts owed to each plaintiff and putative class member. Because the requested relief sought the payment amount of policy benefits, the court held that it could not be sought under section 17200.
Plaintiffs' Motion
Plaintiffs moved for leave to file a motion for reconsideration or, alternatively, for leave to amend. They argued that the court had manifestly failed to consider their argument that the proposed injunction was not a request for payment of policy benefits.
The court found that it had considered that argument and had rejected it based on plaintiffs' allegations that they and the putative class members were entitled to contractual benefits, together with the proposed injunction's request for an order requiring State Farm to determine the payment amount owed under the policies. The court distinguished cases involving injunctions requiring a claims administrator to reopen or investigate claims, explaining that those plaintiffs had not alleged that they were entitled to recover benefits or sought an award of benefits in the district court.
Ruling
The court denied plaintiffs' motion for leave to file a motion for reconsideration. The court also denied without prejudice plaintiffs' alternative request for leave to amend. The court stated that plaintiffs had not submitted a proposed amended complaint or set out the language of any proposed new claim, as required by the district's local rules.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.