Background
Plaintiff Leneice Divinity, proceeding pro se, filed a workers’ compensation claim after a job injury and received disability benefits for several years. An Administrative Law Judge determined she reached maximum medical improvement in March 2019 and was not entitled to further payments. The Mississippi Workers’ Compensation Commission and the Mississippi Court of Appeals affirmed this decision. Divinity subsequently sued the insurance carrier and claims administrator, alleging bad faith for ceasing payments in April 2020. The district court granted summary judgment for the defendants, ruling that the cessation of payments was not in bad faith because the Commission had already determined the benefits were not due.
The court’s reasoning
The court found the appellant’s two arguments unpersuasive. First, the court noted that the district court’s change of the defendant’s name from Summit Holdings to Summit Consulting, LLC was a mere correction of the legal name with no effect on the parties or the merits. Second, the court clarified that summary judgment evidence must be presented in an opposition brief, not at a pretrial conference. The court further observed that the appellant did not summarize the evidence she intended to offer or explain how it would have altered the case’s outcome. The court concluded that the appellant sought to undermine the state court judgment determining she had received all benefits due under the Mississippi Workers Compensation Act.
What it means going forward
The decision reinforces that summary judgment evidence must be submitted in written opposition briefs and that minor clerical corrections to party names do not warrant reversal. It also confirms that federal courts will not relitigate state administrative determinations regarding workers’ compensation benefit entitlements in bad faith claims.
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