Pearl Rodriguez, on behalf of herself and all others similarly situated v. Trumbull Insurance Company, Hartford Insurance Company of the Southeast, and John Does 1 through 21

Summary

The United States District Court for the District of Connecticut denied Pearl Rodriguez’s motion for reconsideration of an order compelling appraisal of her insurance breach-of-contract claim. The court held that Illinois appellate decisions involving fraud claims did not preclude appraisal because Rodriguez’s remaining claim concerned the amount of actual cash value owed for her totaled vehicle. The litigation was stayed pending appraisal, and the parties were ordered to file a status report within 120 days.

Holdings

1. Reconsideration was not warranted because Plaintiff identified no intervening change in controlling law, new evidence, clear error, or manifest injustice.
2. Illinois law does not preclude appraisal where the complaint presents a dispute over the actual cash value of an insured vehicle and does not require resolution of fraud or other legal issues beyond valuation.
3. The Court adhered to its prior ruling compelling appraisal and stayed the litigation pending completion of appraisal proceedings.

Questions Presented

1. Whether reconsideration was warranted because the Court allegedly misapplied Illinois law in compelling appraisal of Plaintiff's insurance-related breach-of-contract claim.
2. Whether Illinois decisions holding that appraisal is inappropriate when claims involve fraud preclude appraisal where the complaint asserts only a dispute over the actual cash value of a totaled vehicle.
3. Whether the litigation should remain stayed pending completion of appraisal.

Disposition

other