Summary Judgment Granted in Favor of Insurer on Bad Faith Claim

In the recent case of Centeno v. American Liberty Insurance Company, No. CV-18- 01059-PHX-SMB, 2019 WL 4849548 (D. Ariz. Oct. 1, 2019), the U.S. District Court for the District of Arizona expounded upon the evidentiary burden a plaintiff must satisfy to demonstrate insurer bad faith.

Centeno was a traveling nurse employed by Beech Home Care ("Beech") and was covered under a policy issued by American Liberty Insurance Company ("American Liberty") providing workers’ compensation coverage. On August 5, 2016, while retrieving medical supplies from her vehicle to continue treatment of a patient, Centeno allegedly fell and injured her back. No one witnessed the injury. Centeno, along with fellow nurse Jeuckstock, continued treating patients that day following Centeno’s alleged injury.

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