Insurers who insist on using biased medical examiners in an effort to routinely deny insurance benefits to injured people may want to consider Hangarter v. Provident Life and Accident Ins. Co., 373 F.3d 998, 1010-1011 (9th Cir. 2004). In that case the 9th Circuit Court of Appeals found that Provident repeated use of the same medical examiner constituted evidence of bad faith on the part of the carrier and may give rise to an action for bad faith against the insurance carrier.