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1200 California Street, Suite 260, Redlands, CA 92374
1200 California Street, Suite 260, Redlands, CA 92374

“Plaintiff claims that Defendant breached the obligation of good faith and fair dealing by failing to pay/delaying payment of benefits due under the insurance policy. To establish this claim, Plaintiff must prove all of the following: 1. That Plaintiff suffered a loss covered under an insurance policy with Defendant; 2. That Defendant was notified of the loss; 3. That Defendant, unreasonably failed to pay/delayed payment of policy benefits; 4. That Plaintiff was harmed; and 5. That Defendant’s failure to pay/delay in payment of policy benefits was a substantial factor in causing Plaintiff’s harm. To act or fail to act “unreasonably” means that the insurer had no proper cause for its conduct. In determining whether [Defendant acted unreasonably, you should consider only the information that Defendant knew or reasonably should have known at the time when it failed to pay/delayed payment of policy benefits.”

[CACI Jury Instructions [citations omitted]]

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Law Offices of James R. Dickinson – 909-848-8448

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