E-Z Mart Stores, Inc. v. Hale
Linda Hale sued E-Z Mart Stores, Inc. for breach of contract and breach of the duty of good faith and fair dealing after E-Z Mart stopped paying her workers' compensation benefits following a workplace injury. E-Z Mart, a nonsubscriber to the Workers' Compensation Act, had implemented a self-insurance program, assuring employees that claims would be handled like traditional workers' compensation. The jury found E-Z Mart breached its contract and duty of good faith, and the trial court awarded Hale significant damages. On appeal, E-Z Mart argued no contract existed and that the duty of good faith did not apply to a self-insured entity. The appellate court affirmed the trial court's judgment, deeming the existence of an implied contract and holding that E-Z Mart, by assuming the role of an insurer, was subject to the duty of good faith and fair dealing. The court also rejected E-Z Mart's statute of limitations defense.