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7^th Circuit Court of Appeals

Case Name: Hartford Accident and Indemnity Company v. Zhen Lin

Case No.: 22-2776

Officials: Easterbrook, Wood, and Pryor, Circuit Judges.

Focus: Insurance

Zhen Feng Lin, a food delivery driver, sustained severe injuries in a car accident. Following the accident, Lin received compensation from the insurance of the at-fault driver and workers’ compensation benefits from Hartford Fire Insurance Company, his employer’s insurer. Lin subsequently pursued additional recovery under his employer’s underinsured motorist policy with Hartford Accident.

The Seventh Circuit upheld the district court’s ruling that Lin and Hartford Accident had not reached a “settlement agreement” as outlined in the insurance policy. Consequently, the court decided that the policy’s limits should be reduced by the amount Lin received in workers’ compensation benefits. Furthermore, the court concurred with the district court’s determination that Lin should be reimbursed for the sum he paid to resolve the workers’ compensation lien.

Moreover, the court affirmed the district court’s dismissal of Lin’s counterclaims alleging bad faith and breach of contract. It found no credible basis supporting the assertion that Hartford Accident unreasonably delayed settling Lin’s claim. Lin’s request for statutory penalties due to Hartford Accident’s alleged delay in processing his claim was also rejected.

Lastly, the court declined to grant sanctions against either party. While Lin’s appeal was deemed partly frivolous, the court chose not to impose sanctions at its discretion.

Affirmed.

Decided 04/01/24

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