Krausman v. Liberty Mutual Ins. Co.

Conn. App. Ct.October 28, 2025No. AC46782Cited 1 time

Defendant WinLiberty Mutual Insurance Company

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Case Details

Judge(s): Elgo; Moll; Harper
Status — whether other courts must follow this ruling: Published
Procedural Posture — the stage the case had reached: appeal

Related Laws

No specific laws identified for this ruling.

Claim Types

Breach of ContractWrongful Termination

Outcome

The appellate court affirmed the trial court's judgment for Liberty Mutual Insurance Company on the plaintiff's CUTPA and implied covenant of good faith and fair dealing claims in an underinsured motorist benefits dispute, though the plaintiff had prevailed on the underlying arbitrated underinsured motorist claim.

Excerpt

The plaintiff insured appealed from the trial court's judgment for the defen- dant insurance company on her amended complaint alleging a violation of the Connecticut Unfair Trade Practices Act and a breach of the implied covenant of good faith and fair dealing in an insurance dispute concerning underinsured motorist benefits. She claimed, inter alia, that the court improp- erly granted the defendant's motion to bifurcate and stay discovery. Held: The trial court did not abuse its discretion in granting the defendant's motion to bifurcate and stay discovery, as the court reasonably could have concluded that bifurcation of the claims served interests of convenience and judicial efficiency and may have negated the need to litigate certain other issues. The trial court did not abuse its discretion in denying the plaintiff's motion for an order of compliance with her discovery requests, as the defendant eventually filed a notice of compliance and the plaintiff did not allege any prejudice resulting from the defendant's delay in complying with her discov- ery requests. This court declined to reach the merits of the plaintiff's claim that the trial court erred with respect to certain legal and factual determinations, as the plaintiff failed to furnish an adequate record for review. The trial court applied a proper legal standard in ruling on the counts of the plaintiff's complaint alleging that the defendant failed to act in good faith pursuant to a provision of CUTPA and that it acted in bad faith in violation of the implied covenant of good faith and fair dealing, as the court reasonably could have concluded, in light of the evidence and the related findings of fact, that the plaintiff failed to satisfy her burden of demonstrating that the defendant had acted in bad faith. Argued October 29, 2024—officially released October 28, 2025

What This Ruling Means

# Krausman v. Liberty Mutual Insurance Company **What Happened** A woman filed a lawsuit against Liberty Mutual Insurance Company over a disagreement about underinsured motorist benefits—insurance coverage that protects you if hit by a driver with insufficient insurance. She claimed the company treated her unfairly and violated consumer protection laws. She also objected to the court's decision to split the case into separate phases and delay gathering evidence. **What the Court Decided** The appeals court sided with Liberty Mutual. It ruled the trial court properly handled the case procedures and that the company did not violate unfair trade practice laws or break the implied promise to deal fairly. Notably, while the plaintiff had won her original arbitration claim for underinsured motorist benefits, the higher court rejected her additional legal claims against the insurance company. **Why This Matters** This ruling shows that even when workers or consumers win initial claims, courts may limit additional legal claims against insurance companies. It demonstrates the importance of understanding insurance policies thoroughly and seeking qualified representation early when disputes arise.

This summary was generated to explain the ruling in plain English and is not legal advice.

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This ruling information is sourced from public court records via CourtListener.com. Case outcomes, claim types, and summaries are extracted using AI analysis and may be incomplete or inaccurate. It is provided for informational and educational purposes only and does not constitute legal advice.

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