Court Wanted To See The Lawyer In ‘Charm School,’ NOT Elementary English Reading Class

A District Court in Kansas held that under a fair reading of the complaint, a defendant may establish the amount in controversy by relying on calculations based on allegations in the complaint, as well as plaintiff’s informal estimates of the amount at issue.

The plaintiff brought a putative class action in state court asserting claims for negligence, fraud, negligent misrepresentations, breach of duty of good faith and fair dealing, breach of contract and unjust enrichment against the defendant, Transamerica Life Insurance Company.  You know, the people with the pointy building in San Francisco.

The plaintiff and putative class members purchased and renewed Long-Term Care (“LTC”) insurance policies from the defendant. The petition defined the class as “all Kansas residents who purchased an LTC policy sold by Transamerica or its predecessor PFL.” The plaintiff contended that when the defendant sold the policies, it knew that the premiums were based on actuarial defects and that it planned to shift the cost of these defects to the policyholders by raising premiums. 

The petition stated that it sought damages only for premium increases due to a “known actuarial defect,” which means “an unreasonable actuarial assumption” that defendant relied on to “increase premium rates.” The petition stated that the total amount of increases in premiums on the LTC policies at issue in this lawsuit was $6,441,652, and that the total amount of increases in premiums on the LTC policies at issue in this lawsuit was approximately $2.5 million–the amount of premium increases that the plaintiff alleged were attributable to the known actuarial defects.

The defendant removed the case to the federal court under CAFA. The plaintiff moved to remand, which the District Court denied.

The defendant, producing the affidavit of its Senior Vice President and Chief Actuary argued that the plaintiff’s purported limitation of damages to $2.5 million was no limitation at all, and that it put more than $33 million of premium increases in play. The Notice of removal stated that Kansas residents owned, a total of 4,407 LTC policies issued by the defendant, and as of December 31, 2010, the defendant had collected $33,656,813 attributable to rate increases, and that as of December 31, 2009, the Kansas Department of Insurance (“DOI”) had approved premium rate increases of approximately $6,441,652 per year on the LTC policies in question.

The Court observed that fair reading showed that the petition claimed damages for relevant premium increases, i.e. increases due to known actuarial defects over the life of the policies in question, not just the increases from a single year. The petition alleged that the “total amount of increases in premiums on the LTC policies at issue in this lawsuit was $6,441,652.” No other allegation confined the plaintiff’s damages to premium increases in just one year. Thus, the question before the Court was how much of the total premium increases the petition put at issue.

The defendant contended that the petition put at issue all premium increases on the LTC policies at issue– more than $33 million. 

The plaintiff disagreed and argued that because the petition was limited to premium increases due to known actuarial defects, it put at issue only $2.5 million. The plaintiff asserted that “any adult reasonably well-acquainted with the English language sharing defendant’s views should turn in their (sic) literacy card and enroll in an elementary English reading class.” 

Disagreeing with the plaintiffs, the Court suggested that “any lawyer who engages in such rhetoric should turn in his or her bar card and enroll in charm school.”

The Court remarked that the plaintiff was “attempting to have it both ways” by pleading an amount below the requisite amount in controversy while leaving the door open for the class to seek damages above the jurisdictional amount. Even though the plaintiff limited his claims to damages for premium increases attributable to known actuarial defects, the petition left open the opportunity for plaintiff to assert that all premium increases were due to known actuarial defects.  Thus, the Court concluded that the plaintiff’s purported lim

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Gun Rights Advocates Wary of Control

Regular Photo Size Senator’s Handling of Her Gun Draws… ATF to Require Gunbuyer Info on Border Admin. to Propose Steps on Gun Safety Fed Failure Inflames Gun Control Debate No Action from Obama on Guns Agents: We Were Ordered to Let Guns Go Gov Outraged over Border Weapons Report Report Criticizes ATF Gun Operation 7/10 Guns in Mexico Came from U.S. < Find more…


An Eloquent How-to Manual for Strong Legal Writing

Novelist Elmore Leonard once said about his writing, I leave out the parts that most people skip.1 His statement, at once so simple and so quizzical, could as easily have come from either Buddha or Yogi Berra. Leonard17s point, however, is clear. Lean writing is strong writing.

For many lawyers, lean writing is anathema. Why use one word when we can string together several? Why use a simple word when an obtuse one is available? If we can say it in Latin, let17s do. And when in doubt, Capitalize. For a profession so grounded in writing, lawyers often are not very good at it.

Recognizing bad writing is easy.

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“Injustice” Premieres Tonight on the Reelz Channel

Just a few weeks after the release of “Hot Coffee”, a pro-plaintiff film on HBO, a documentary on greed and corruption in the American lawsuit industry called “Injustice” will premiere tonight at 10pm EDT on the Reelz Chanel (238 on DirectTV, 299 on Dish, check your local listings for other providers).

The film raises important questions about the role of lawsuits in America and the motives behind them. “Injustice” will run through early December, with eight additional airings after its premiere.

For more information go to


IMPD arrest tied to Don’s Guns theft

INDIANAPOLIS (WISH) – An Indianapolis Metropolitan Police Department arrest on Tuesday morning is connected to the theft of a pink handgun from a popular gun store, officials say.

Don’s Guns, 3807 Lafayette Road, says a woman walked into the store Monday afternoon . She asked to view a .380-caliber handgun with a pink handle and ran off with it .

Police say it all started when a woman was caught trying to shoplift from King Beauty Supply on Arlington Avenue. She pulled out a handgun and threatened the store’s employees before fleeing to her car. E

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