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Schuetta v. Aurora National Life Assurance Co.

Citations: 27 F. Supp. 3d 949; 2014 U.S. Dist. LEXIS 63750; 2014 WL 2873200Docket: Case No. 13-CV-1007-JPS

Court: District Court, E.D. Wisconsin; May 8, 2014; Federal District Court

Narrative Opinion Summary

This case involves a former employee of Dana Corporation who filed a lawsuit against Aurora National Life Assurance Company after a dispute over annuity benefits. The primary legal issues include breach of contract, equitable estoppel, breach of the implied duty of good faith and fair dealing, and negligence. After a series of procedural developments, including the dismissal of certain claims and denial of motions to amend the complaint, the court addressed Aurora's motion for summary judgment on the remaining claims. The court granted summary judgment in favor of Aurora on the breach of contract and negligence claims, citing the absence of a breach and the application of the economic loss doctrine, respectively. However, the court denied summary judgment for equitable estoppel and breach of the implied duty of good faith, highlighting Aurora's potential failures to inform Mr. Schuetta of his annuity obligations. The case will proceed to trial on these two claims, with the possibility of further motions as the parties continue to explore the facts surrounding Aurora's actions and Mr. Schuetta's reliance on them.

Legal Issues Addressed

Accord and Satisfaction

Application: The court concluded that there was no accord and satisfaction because Aurora's payment to Mr. Schuetta did not resolve a disputed claim, as it did not offer any additional consideration.

Reasoning: Aurora did not offer the check to resolve a disputed claim with Mr. Schuetta, as there was no dispute regarding his entitlement to benefits from December 1, 2012.

Breach of Contract

Application: The court found that Mr. Schuetta failed to demonstrate a breach of the annuity contract's terms as he did not submit the required benefit election form until 2012.

Reasoning: Mr. Schuetta has not identified any specific provision of the contract that Aurora breached. The contract's clear language necessitates that he elect a payment option to start receiving benefits.

Breach of Implied Duty of Good Faith

Application: The court found that there was sufficient evidence of Aurora's failure to inform Mr. Schuetta about necessary actions related to his annuity, allowing this claim to proceed.

Reasoning: Evidence suggests that Aurora failed to correct Mr. Schuetta's misunderstanding regarding his annuity and did not inform him about necessary actions related to the rehabilitation plan.

Economic Loss Doctrine

Application: The court applied the economic loss doctrine to dismiss Mr. Schuetta's negligence claim, as the duty owed by Aurora arose solely from the contractual relationship.

Reasoning: Any duty owed by Aurora to Mr. Schuetta arose solely from their contractual relationship. Therefore, the Court grants Aurora’s motion for summary judgment, resulting in the dismissal of Mr. Schuetta’s negligence claim.

Equitable Estoppel

Application: The court determined that there was sufficient evidence of non-action by Aurora in 1990 and 1994, potentially leading Mr. Schuetta to reasonably rely to his detriment, allowing this claim to proceed.

Reasoning: The relevant events include Mr. Schuetta's 1990 inquiry and letter to Aurora regarding perceived errors in his annuity, and Aurora’s provision of a rehabilitation plan in 1994.