State Farm chastised for "disingenuous" actions in delaying payment of PIP benefits
Woodrow Byers was a bail bondsman employed by his wife's corporation until he suffered a severe knee injury in a motor vehicle collision. State Farm stopped paying PIP benefits because it believed that he was continuing to work for his wife's business, even though he wasn't paid, a substitute "bounty hunter" was employed, and the medical testimony was undisputed regarding Byers' inability to work as a "bounty hunter." On the eve of trial, State Farm finally paid for Byers' knee surgery--one year late--in what the court concluded was a calculated attempt to avoid defending the delay at trial. The jury still awarded Byers' wage loss, a modest recovery for domestic service losses, and interest. When the Court awarded attorneys' fees relating to the "overdue" medical benefits, State Farm appealed both the jury verdict and the Court's fee award.
Both the trial court and the Court of Appeals described State Farm's defenses as "disingenuous" and its delay in payment of PIP benefits "unreasonable". The fee award of $70,000.00 was upheld. The appellate court also upheld the lower court's decisions in refusing to allow State Farm to raise irrelevant arguments about Byers' wife's management of her corporation.