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Patterson v. Metropolitan Life Insurance Co.

United States District Court, N.D. Alabama, Northwestern Division

December 20, 2017




         Shortly before his mother died, Aaron Patterson called Metropolitan Life Insurance Company to request another copy of his mother's life insurance policy. MetLife sent an “Acknowledgment of Insurance, ” which incorrectly stated the face value of the policy as $250, 000, when the correct value was $25, 000. In light of Patterson's belief that MetLife is bound by its mistake and should pay $250, 000 instead of the actual face value, Patterson filed this lawsuit, alleging breach of contract and bad faith.[1] Doc. 1. The parties filed motions for summary judgment, which are fully briefed and ripe for consideration. Docs. 20; 21; 22; 23; 24; 26; 27; 28; 29. After reading the briefs, viewing the evidence, and considering the relevant law, the court grants summary judgment for MetLife.


         Under Rule 56(a) of the Federal Rules of Civil Procedure, summary judgment is proper “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56. “Rule 56[] mandates the entry of summary judgment, after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish the existence of an element essential to that party's case, and on which that party will bear the burden of proof at trial.” Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986) (alteration in original). The moving party bears the initial burden of proving the absence of a genuine issue of material fact. Id. at 323. The burden then shifts to the nonmoving party, who is required to “go beyond the pleadings” to establish that there is a “genuine issue for trial.” Id. at 324 (internal quotations omitted). A dispute about a material fact is genuine “if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986).

         At summary judgment, the court must construe the evidence and all reasonable inferences arising from it in the light most favorable to the non-moving party. Adickes v. S. H. Kress & Co., 398 U.S. 144, 157 (1970); see also Anderson, 477 U.S. at 255. Any factual disputes will be resolved in the non-moving party's favor when sufficient competent evidence supports the non-moving party's version of the disputed facts. See Pace v. Capobianco, 283 F.3d 1275, 1276, 1278 (11th Cir. 2002). However, “mere conclusions and unsupported factual allegations are legally insufficient to defeat a summary judgment motion.” Ellis v. England, 432 F.3d 1321, 1326 (11th Cir. 2005) (per curiam) (citing Bald Mountain Park, Ltd. v. Oliver, 863 F.2d 1560, 1563 (11th Cir. 1989)). Moreover, “[a] mere ‘scintilla' of evidence supporting the opposing party's position will not suffice; there must be enough of a showing that the jury could reasonably find for that party.” Walker v. Darby, 911 F.2d 1573, 1577 (11th Cir. 1990) (citing Anderson, 477 U.S. at 252)). The standards governing cross-motions for summary judgment are the same, although the court must construe the motions independently, viewing the evidence presented by each moving party in the light most favorable to the non-movant. See U.S. v. Oakley, 744 F.2d 1553, 1555 (11th Cir. 1984).


         Gail Patterson purchased a life insurance policy from MetLife with a face value of $25, 000, naming her son Aaron Patterson as the lone beneficiary. Doc. 21-1 at 6-35. The policy states that “[t]his policy includes any riders and, with the application attached when the policy is issued, makes up the entire contract. . . . No statement will be used to contest the policy unless it appears in the application.” Doc. 21-1 at 18. After obtaining the policy, Gail Patterson consistently paid the monthly premiums until her death in September 2015. Doc. 21-1 at 37-41. Sometime before her death, her health gradually deteriorated, and Aaron Patterson began handling her affairs. Doc. 24-1 at 9.

         Aaron Patterson knew that his mother had a life insurance policy with MetLife, but had never seen the policy and did not know the face amount of the coverage. Doc. 26 at 4-5. On March 9, 2015, around the time his mother entered a nursing home, he called MetLife to request a copy of the policy. Docs. 21-2 at 2; 21-4 at 9. One of MetLife's customer service representatives, Lane Wiley, told Patterson that “what we normally do is send out an Acknowledgement of Insurance (“AOI”), which is a legal document providing the policy information. For an exact duplicate of the entire policy, there is a 25 dollar fee.” Doc. 21-2 at 2. Patterson declined to pay the fee to receive the exact duplicate, so that same day MetLife mailed to Gail Patterson the one-page AOI, which incorrectly listed the face amount of the policy as $250, 000. Docs. 21-2 at 2-3; 21-1 at 43.

         The cover letter accompanying the AOI reads: “We are enclosing the Acknowledgment of Insurance you requested. The acknowledgment serves the same legal purpose as the original life insurance policy.” Doc. 24-26 at 8. The AOI states that “[t]he original Policy, together with the application upon which it was based, is the entire contract between the Company and the Owner” and that the AOI is only “a brief description of the Policy.” Doc. 21-1 at 43. The AOI also explains that “[a]ny additional benefits contained in the Policy are not described here” and that “[f]urther details about the policy and benefits will be furnished upon request.” Doc. 21-1 at 43.

         After his mother's death, Patterson called MetLife to file a claim. Docs. 1-1 at 3; 21-4 at 2-3. When the MetLife representative indicated that the estimated benefit was approximately $30, 000-i.e. the $25, 000 face value plus the yearly dividends, as authorized by the policy, doc. 21-4 at 3-Patterson responded, “[t]hat's what I was wondering because on this piece of paper that we received March 9th, 2015 . . . has the face amount of insurance [as] $250, 000.” Doc. 21-4 at 3. The MetLife representative explained that this figure was a mistake and that “[the representative] just added another zero. . . . Or the decimal is missing or out of place. . . . $25, 000 is the face amount.” Docs. 21-1 at 14; 21-4 at 3. Patterson said “Okay, ” and the call concluded shortly thereafter. Doc. 21-4 at 3.

         MetLife subsequently sent Patterson a letter approving his claim and a check for $30, 030.66. Doc. 21-1 at 53. The letter noted that the AOI had “incorrectly listed the policy face amount” and that the correct amount was $25, 000. Doc. 21-1 at 51-53. MetLife included with the letter the annual policy statements for the previous five years it had sent to Gail Patterson, which all showed the face value as $25, 000. Docs. 21-1 at 45, 53. Patterson subsequently filed this lawsuit seeking to recover the full amount referenced in the AOI. Doc. 1.

         III. ANALYSIS

         There are no material facts dispute in this case. Therefore, the court must decide which party is entitled to judgment as a matter of law. Fed.R.Civ.P. 56. Because this matter is before the court based on diversity jurisdiction, the court applies Alabama's substantive law to each claim. Erie R. Co. v. Tompkins, 304 U.S. 64, 78 (1938).

         A. ...

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