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Interesting Opinion Ordering Bench Trial – N.D. Il.

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  • Interesting Opinion Ordering Bench Trial – N.D. Il.

    Interesting Opinion Ordering Bench Trial – N.D. Il.

    Attached is an opinion out of the Northern District of Illinois, Hutten v. ReliaStar Life Insurance Company. Without going into the specific facts, what is interesting about this case is the fact that the judge decides that both motions for summary judgment should be denied and orders a bench trial.

    Throughout his claim and appeals process, Hutten has advocated a variety of conditions to support his long-term physical disability claim. However, on summary judgment, he argues that he is entitled to benefits due to his dementia and/or his back condition. (Dkt. 49). Significant factual disputes remain at this stage such as whether Hutten has dementia, what the cause of the dementia is, when the dementia began, does Hutten have a disabling back condition, to what extent does it prevent him from performing his duties as a software developer, and at what time did the back condition begin to limit his ability to work. Because of this, the Court finds this matter is not amenable to summary judgment and instead the Court must sit as a finder of fact at a bench trial.

    As presented to the Court, the matter is rife with factual disputes. One need look no further than the voluminous fact section in each party’s brief that present markedly different accounts of Hutten’s medical history, treatment, and diagnosis. To support their arguments regarding the above questions, the parties present several competing medical opinions and dispute multiple factual issues fundamental to the outcome. Unsurprisingly, these opinions reach diametrically opposed conclusions leaving the Court to weigh the credibility of each opinion and independently evaluate the Hutten’s purported medical conditions and their most likely causes. The Court is more than capable of conducting such an assessment, but summary judgment is simply not the proper vehicle to do so. It is not within the court’s authority to “make credibility determinations, weigh the evidence, or decide which inferences to draw from the facts” at summery judgment, rather “these are jobs for a factfinder.” Payne v. Pauley, 337 F.3d 767, 770 (7th Cir. 2003) (citing Anderson, 477 U.S. at 255); see also Uddeholm Corp., 32 F.3d at 1099 (“This language leaves no question that the district court improperly weighed the evidence in this case in arriving at its decision to grant summary judgment. … [T]he appropriate proceedings for such fact-finding is a bench trial and not the disposition of a summary judgment motion.”); cf. Kearney v. Standard Ins. Co., 175 F.3d 1084, 1095 (9th Cir. 1999) (en banc) (“The district judge will be asking a different question as he reads the evidence [at trial], not whether there is a genuine issue of material fact, but instead whether [the plaintiff] is disabled within the terms of the policy. …. [T]rial on the record, even if it consists of no more than the trial judge rereading what he has already read, and making findings of fact and conclusions of law instead of a summary judgment decision, may have real significance.”).

    The Federal Rules of Civil Procedure and controlling authority leave little doubt — “if material evidence conflicts, then there must be a trial.” Krolnik, 570 F.3d at 843. The parties offer conflicting evidence and it is not permissible at this juncture for the Court to wade into the waters of a finder of fact. Waldridge, 24 F.3d at 920 (“The court has one task and one task only: to decide, based on the evidence of record, whether there is any material dispute of fact that requires a trial.”). Accordingly, the Motions for Summary Judgment must be denied.
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