Bad Faith Claim Barred By Statute Of Limitations, Federal Judge Determines
SAN DIEGO - A California federal judge on Dec. 10 dismissed a disability claimant's bad faith claim after determining that the claim is barred by the applicable two-year statute of limitations because accrual of the bad faith claim began when the insurer issued its initial benefits determination and not when the insurer issued its decision on appeal (Frank L. Pavel v. Unum Life Insurance Company of America, et al., No. 18-1778, S.D. Calif., 2018 U.S. Dist. LEXIS 209019).