Parties: Respondents Dung Truong and Thuan Nguyen sued Jeweler’s Mutual Insurance Company for failing to pay insurance after a jewelry theft during their trip to Vietnam.
Insurance Policy: The respondents insured six jewelry pieces valued at $502,100 under a policy issued by Jeweler’s Mutual. The jewelry was stolen in 2015, and a claim for the full insured amount was filed.
Dispute: Jeweler’s Mutual did not allege any misrepresentation in the insurance application but required the respondents to prove they owned the jewelry, which they failed to accept as sufficient.
Trial Decision: The trial judge found in favor of the respondents, awarding them $502,100 in compensatory damages and $45,000 in punitive damages, criticizing Jeweler’s Mutual for acting in bad faith by forcing the respondents to prove pre-policy ownership, despite having accepted their ownership at the time of policy issuance.
Appeal: Jeweler’s Mutual appealed, arguing:
The punitive damages were unjustified.
The compensatory damages were wrongly assessed.
Appeal Outcome: The Court of Appeal upheld the trial decision, finding:
The insurer acted in bad faith by challenging ownership after issuing the policy, imposing unreasonable demands.
No error was made in assessing compensatory damages based on the appraised value of the jewelry since the insurer provided no evidence that actual cash value would have been less.
Costs: $15,000 in costs awarded to the respondents.
