Commissioner of Insurance v. North Carolina Rate Bureau
Court of Appeals of North Carolina
124 N.C. App. 674 (N.C. Ct. App. 1996)
The North Carolina Rate Bureau (plaintiff) requested increased automobile and motorcycle insurance rates of return, but the insurance commissioner (defendant), applying statutory accounting principles instead of GAAP and relying solely on an expert witness's cost and expense findings over the Bureau's own conflicting findings without resolving the discrepancy, reduced the requested rates instead of approving them. The Bureau appealed, challenging both the commissioner's use of the accounting method and the sufficiency of the evidence supporting the reduced rates.
Whether a state decision reducing a requested insurance rate of return must be supported by material and substantial evidence.