Rangel v. Hartford Accident & Indemnity Co.
Lorenzo Rangel appealed a summary judgment granted in favor of Hartford Accident & Indemnity Company regarding his bad faith claim. Rangel alleged Hartford delayed workers' compensation payments following a job-related accident in May 1988, with payments ceasing in October 1988 and resuming in February 1989 after an Industrial Accident Board (IAB) conference. The underlying compensation claim was settled for $29,000, and the Compromise Settlement Agreement (CSA), approved by the IAB, noted that the carrier's liability or extent of injury was uncertain. Hartford successfully moved for summary judgment based on collateral estoppel, arguing Rangel was precluded from relitigating the issue of uncertainty. The appellate court affirmed the summary judgment, concluding that the IAB's finding of uncertainty of liability provided a reasonable basis for Hartford's delay in payments, thus defeating Rangel's bad faith claim.