9th Circuit Dismisses Worker's Bad-Faith Claim Against Carrier as Untimely

A federal appeals court upheld the dismissal of a worker’s bad-faith claim against her employer’s insurance carrier as untimely, but it declined to assess attorney fees against her. Case: Dorfmeister v. Zurich American Insurance Co., No. 20-16776, 11/22/2021, unpublished. Facts and procedural history: Bridget Dorfmeister filed a bad-faith claim against Zurich American Insurance Co. in a federal trial court in Arizona after the carrier denied her claim for workers’ compensation benefits. Zurich had issued a notice of denial on June 5, 2017, and closed Dorfmeister&rsquo...