Narrative Opinion Summary
In this case, the appellants, Bobbie J. Nabors and Carl Nabors, challenged the trial court's summary judgment in favor of The Travelers Insurance Company regarding claims of outrageous conduct. Mrs. Nabors sustained a back injury and settled with Travelers for future medical benefits. After a subsequent incident at a new job, Travelers terminated her benefits without further investigation, leading to the denial of medical services. The Naborses alleged that Travelers' termination of benefits constituted outrageous conduct, arguing that the insurer's actions were intentional and reckless. The trial court found no substantial evidence to support these claims, citing that the conduct did not rise to the level necessary to be deemed atrocious and intolerable under the tort of outrageous conduct, as articulated in Lowman v. Piedmont Executive Shirt Manufacturing Co. The court held that reasonable individuals could not disagree on the absence of extreme and outrageous behavior, thus affirming the summary judgment for Travelers. Consequently, the appeal was denied, and the insurance company's decision was upheld, leaving Mrs. Nabors without coverage and Mr. Nabors responsible for the medical expenses. This decision underscores the high threshold required to establish claims of outrageous conduct against insurers.
Legal Issues Addressed
Summary Judgment Standardsubscribe to see similar legal issues
Application: The court affirmed the summary judgment for the insurance company, finding that there was no genuine issue of material fact as to whether the insurer's conduct was outrageous.
Reasoning: The trial court granted summary judgment for Travelers, leading to the current appeal, where the Naborses argue that substantial evidence supports their claims of outrageous conduct.
Threshold for Outrageous Conductsubscribe to see similar legal issues
Application: The court determined that the actions of the insurance company did not meet the high threshold required for outrageous conduct, as there was no substantial evidence to show the conduct was extreme and intolerable.
Reasoning: Recovery is limited to conduct that is considered atrocious and intolerable in civilized society. A review of the trial court's evidence revealed no substantial proof of such conduct, as it did not meet the necessary threshold where reasonable individuals could disagree on its existence.
Tort of Outrageous Conduct Against an Insurersubscribe to see similar legal issues
Application: The court examines whether the insurance company's actions were extreme and outrageous enough to warrant a claim for the tort of outrageous conduct.
Reasoning: A claim for the tort of outrageous conduct against an insurance company is permissible despite workman’s compensation statutes, as clarified in Lowman v. Piedmont Executive Shirt Manufacturing Co.