American Family Insurance Group v. Ford

293 N.E.2d 524, 155 Ind. App. 573, 1973 Ind. App. LEXIS 1258
CourtIndiana Court of Appeals
DecidedMarch 22, 1973
Docket472A182
StatusPublished
Cited by11 cases

This text of 293 N.E.2d 524 (American Family Insurance Group v. Ford) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Family Insurance Group v. Ford, 293 N.E.2d 524, 155 Ind. App. 573, 1973 Ind. App. LEXIS 1258 (Ind. Ct. App. 1973).

Opinion

White, J.

This is an appeal from a judgment declaring that an automobile insurance policy issued by defendant-appellant Insurance Company (company) insuring plaintiff-appellee Dennis R. Ford (insured), was in effect on March 2, 1970, the date of a collision in which he was involved while driving the automobile described in the policy.

The only issue before the lower court at the trial was whether the policy had been cancelled (for non-payment of premium) prior to the date of the accident. 1 The trial court’s general findings for the insured-plaintiff implied the specific finding that the evidence failed to prove cancellation. Because we cannot weigh the evidence and because we cannot say that the evidence is without conflict and leads unavoidably to the conclusion that the policy was cancelled, we affirm.

Exhibit A to plaintiff-appellee-insured’s complaint was an automobile insurance policy which, for the purpose of this dispute and this opinion, must “be considered as if written for a policy period or term of six (6) months” commencing September 16, 1969, and ending March 16, 1970. 2 The insurer’s answer admitted that the policy had been “in force” but denied that it was in force on March 2, 1970. In a second defense the company alleged that it had *576 issued the policy “for the period from September 16, 1969 until December 16, 1969, and for such periods of time thereafter as plaintiff herein might pay the premium for said policy.” And further alleged cancellation by written notice to insured for non-payment of premium on or about January 21, 1970, and that the policy was not in force on March 2, 1970. 3 In choosing to affirmatively plead cancellation as a second defense, counsel were wise. The defense is one of confession and avoidance, an affirmative defense which must be specially pleaded.

Trial Rule 8(C) provides in pertinent part:

“A responsive pleading [to a claim for relief, TR. 8(A)] shall set forth affirmatively and carry the burden of proving: Accord and satisfaction, . . . discharge in bankruptcy, . . . failure of consideration . . . payment, release, . . . and any other matter constituting an avoidance, matter of abatement, or affirmative defense. A party required to affirmatively plead any matters . . . shall have the burden of proving such matters . . . (Our emphasis.)

While not specifically mentioned in the score or more of defenses listed in TR. 8(C) (most of which we have omitted from the above quotation), cancellation is definitely in the class of new matter which has always required special pleading to make it admissible in evidence as a defense to an action on a contract. In Mabin v. Webster (1891), 129 Ind. 430, 431, 28 N.E. 863, 864, it was held to be reversible error to strike a paragraph of answer alleging rescission:

“The rescission of the contract was a proper defence to be pleaded to the action, and such defence was not admissible under any other paragraph of answer. [Which included a general denial.]
“A plea alleging a rescission of contract is an affirmative plea. It admits the making of the contract, and alleges a rescission of it.”

*577 Storer v. Markley (1905), 164 Ind. 535, 537, 73 N.E. 1081, states that:

“. . . rescission of a contract is an affirmative defense, and when relied upon must be specially pleaded. Mabin v. Webster (1891), 129 Ind. 430, 28 Am. St. 199; Jordan v. Indianapolis Water Co. (1902), 159 Ind. 337; 18 Ency. Pl. and Pr., 849.”

The Jordan case, cited immediately above in Storer v. Markley applied the rule to a defense of abandonment. Rescission, abandonment, and cancellation are words which describe events occurring subsequent to the inception of a contract and which terminate its legal existence. “Cancellation, generally stated, is a right to rescind, abandon or cancel a contract of insurance. . . .” State v. Larson (1943), 152 Fla. 729, 730, 12 So. 2d 896, 897.

“Abandonment of a contract as a defense is by way of confession and avoidance and not a direct denial of any element essential to the proof of the plaintiffs’ main case. Where the defense rests on a rescission or mutual abandonment of a contract, the issue is whether the contract has ceased to have legal existence or has been terminated by reason of events occurring subsequent to the inception of the contract. It is a distinct and substantive ground of defense which ‘must be alleged in the answer according to the provisions of the Practice Act, if a defendant seeks to avail himself of it in order to defeat a recovery on a contract.’ ” Mark v. Stuart-Howland Co. (1917), 226 Mass. 35, 115 N.E. 42, 44, 2 A.L.R. 678, 681.

Although the burden was clearly on the company to prove its defense of cancellation that point has little significance at this time in this case. If the burden were on insured to disprove cancellation, the burden was discharged. The evidence was sufficient to sustain a finding that the policy was not cancelled. The evidence to that end was the insured’s testimony that he did not receive notice of cancellation prior to the accident. It was, of course, not necessary that he actually received notice of cancellation for it to be effective as a determinant of the policy’s legal existence. Ey *578 both policy provision and statute, proof of mailing is sufficient. 4 But just as proof of proper mailing of a communication justifies the inference that it was received in due course, proof that it was not received justifies the inference that it was never mailed. 5 We do not hold, of course, that insured proved he did not receive the cancellation notice or the subsequent letter which might have informed him of it. But he so testified and if the trial judge believed him that was proof. 6 But even with the trial judge believing him, the presumption of non-mailing might have been overcome by convincing evidence of mailing.

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Cite This Page — Counsel Stack

Bluebook (online)
293 N.E.2d 524, 155 Ind. App. 573, 1973 Ind. App. LEXIS 1258, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-family-insurance-group-v-ford-indctapp-1973.