Cantrall
Cantrall v. Hartford Financial Services Group
Opinion
Opinion
MEMORANDUM
In this diversity putative class action, Plaintiff Jessica Cantrall files suit against Defendants Hartford Financial Services Group and several affiliated Hartford entities. Cantrall purports to represent a class of California consumers who allege that they were charged more for cell phone insurance from 2001 to July 2005 than the rates that the Hartford defendants filed by statute with the California Department of Insurance. The district court dismissed Cantrall’s Complaint on California statute of limitations grounds. We affirm the district court’s decision.
Cantrall filed this action well after the applicable four-year statute of limitations expired in 2009. California courts generally do not apply the discovery rule to toll a statute of limitations where public filings, required by statute, contain the information relevant to a claim. See Util. Cost Mgmt. v. Indian Wells Water Dist., 26 Cal.4th 1185 , 114 Cal.Rptr.2d 459 , 36 P.3d 2, 10 (2001). Hartford published a completed rate application in 2004, which was required by the California Insurance Code. See Cal. Ins.Code § 1861.05 (“Every insurer which desires to change any rate shall file a complete rate…