The complaint also points to TDIC’s ownership. It alleges the carrier is a captive insurer owned, through a holding company, by the California Dental Association, and that it “paid dividends to CDAHCI totaling approximately $39.4 million during the period 2017 through 2021.” That structure, Skaggs argues, gave TDIC a financial reason to defeat a verdict she estimates would top $10,000,000.

