“Confirmed Judges, Confirmed Fears” is a blog series documenting the harmful impact of President Trump’s judges on Americans’ rights and liberties.
In December 2018, Trump judge Joan Larsen dissented from a 2-1 ruling reversing a judgment that severely limited punitive damages for a mother who was intentionally and improperly denied an insurance death benefit and improperly granted reduced punitive damages.
Thomas Lindenberg died in 2013. As part of his divorce agreement with Tamarin Lindenberg, Tamarin was the primary beneficiary of his life insurance policy. A month after Thomas died, Tamarin filed a claim with Jackson National Life Insurance Company to collect the death benefit from the policy. The insurance company declined and several months of back-and-forth communication followed without resolution. As a result of the impasse, Tamarin sued the insurance company — individually and as guardian of her and Thomas’ children. Tamarin also sought punitive damages against the company for its unjustified refusal to pay the death benefit.
The district court ordered the insurance company to pay the policy benefit of $350,000 with interest. In addition, the jury in the case found that the insurance company breached its contract and the company’s refusal to pay the insurance claim was in bad faith, intentional, reckless, malicious or fraudulent. The jury ultimately awarded Tamarin punitive damages against the insurance company in the amount of $3 million. But based on a Tennessee law that limited the amount of punitive damages that could be received, the court severely reduced — by $2.3 million — the amount of punitive damages that the insurance company would pay to Tamarin and her children.
Both sides appealed. The Sixth Circuit majority in Tamarin Lindenberg v. Jackson National Life Insurance Company vacated the judgment as to punitive damages, remanded to the district court to recalculate the punitive damages in accordance with the jury verdict, and concluded that the Tennessee statutory cap “violated the individual’s right to a trial by jury in the Tennessee constitution.” The majority also found that the insurance company’s “refusal to pay had no apparent basis under the law” and was “at least reckless,” clearly justifying significant punitive damages. Larsen, on the other hand, argued in dissent that the court should uphold the Tennessee damages limit and the severely reduced trial court judgment against the insurance company.