Hatchwell v. Blue Shield of California

In Hatchwell v. Blue Shield of California (1988) 198 Cal. App. 3d 1027, a wife sought to join her husband in suing their medical insurer on the claim that the insurer had wrongfully denied benefits to her husband. The court held that she had no standing to sue the insurer . The benefits that were the subject of the claim belonged to her husband, not her. This result flowed even though wife was a coinsured under the policy (i.e., entitled to dependent benefits); however, on this particular claim, she was not the claimant and that was enough to deprive her of standing. In sum, a husband and wife sued the insurer over an alleged failure to pay medical benefits to the insured husband. The complaint contained causes of action based on contract, bad faith, breach of fiduciary duty, breach of warranty, negligence, and fraud. As is true here, the wife asserted that she had been part of the policy decision and that premiums were paid from community funds. The trial court granted the defendant's motion for summary judgment against the wife on the ground of lack of standing and the Court of Appeal affirmed. It rejected the wife's arguments that her status as an "intended beneficiary," a " 'dependent beneficiary,' " or a "coinsured" gave her the right or power to sue based on the contract. (Hatchwell, supra, 198 Cal.App.3d at pp. 1032, 1034.) It also rejected the argument that the payment of premiums from community funds was a significant factor favoring relief. (Id. at p. 1036)