Card v. Chase Manhattan Bank

175 Misc. 2d 389, 669 N.Y.S.2d 117, 1996 N.Y. Misc. LEXIS 595
CourtCivil Court of the City of New York
DecidedMay 10, 1996
StatusPublished

This text of 175 Misc. 2d 389 (Card v. Chase Manhattan Bank) is published on Counsel Stack Legal Research, covering Civil Court of the City of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Card v. Chase Manhattan Bank, 175 Misc. 2d 389, 669 N.Y.S.2d 117, 1996 N.Y. Misc. LEXIS 595 (N.Y. Super. Ct. 1996).

Opinion

[390]*390OPINION OF THE COURT

Martin M. Solomon, J.

The pro se plaintiffs commenced, this action against Chase Manhattan Bank (hereinafter referred to as Chase) by endorsed complaint. The action is for breach of contract for failure to provide LifePlus Credit Insurance for Chase Cardmembers coverage to plaintiffs. The complaint alleges: “Failure to provide insurance coverage for fees rendered. Breach of contract. Failure to foward [sic] appropriate fees to Chase Life Plus.”

The action seeks money damages in the sum of $7,700, which appears to be the approximate balance due on the credit card accounts at issue at the time the action was commenced. There does not appear to have been any activity on these accounts since the commencement of the action other then the continued accrual of interest.

In defense of the action, defendant asserts that “No contract existed between Chase and the plaintiffs to provide any fees, money, remuneration or reimbursement with regard to the indebtedness incurred by plaintiffs through the use of Visa and Master Cards issued by Chase.” In addition, the answer alleges that the pro se endorsed complaint fails to state a cause of action against Chase.

Defendant counterclaimed against the plaintiffs for the balance due on the credit card accounts. As of the date of the answer, there was $5,352.56 due on the Visa account at issue and $2,711.31 due on the Mastercard account at issue. The plaintiffs do not dispute that these balances are due and owing on these accounts.

The action was tried to the court on April 8, 1996. The plaintiffs testified on their own behalf, Robert Riley, employed by defendant as a credit analyst, testified for the defendant. Mr. Riley’s duties include investigating disputes and delinquent notices and he testified that he was familiar with the LifePlus Credit Insurance for Chase Cardmembers plan.

Plaintiff Cindy Card obtained the Visa and Mastercard from the defendant in 1989 and 1990. It is undisputed that Ms. Card was the primary cardholder throughout the existence of these accounts, Kermit Card was the cosigner on these accounts. At the time of the opening of the accounts, Ms. Card was solicited by the defendant to purchase LifePlus Credit Insurance for Chase Cardmembers for these accounts. Ms. Card accepted the credit insurance coverage at the time she opened these accounts.

[391]*391Defendant posted a charge each month against each credit card for the credit insurance coverage. Defendant collected the payment each month for the credit insurance on each card. These charges and payments continued from 1989 until activity on the cards ceased in or about 1994.

Ms. Card was employed from 1989 through August of 1993. In August of 1993 Ms. Card became unemployed. In August of 1993 the LifePlus Credit Insurance for Chase Cardmembers plan was in full force and effect on both accounts.

The plaintiffs never received any insurance policy or certificate of insurance for LifePlus Credit Insurance for Chase Card-members in connection with the credit card insurance. After Ms. Card became unemployed she attempted to have the Life-Plus Credit Insurance for Chase Cardmembers coverage pay her monthly credit charges pursuant to the advertisement and solicitation she received.

Plaintiffs made repeated requests for insurance information from the defendant. Plaintiffs twice requested relevant documents from defendant by letter, the first nearly one year prior to trial. Defendant never responded to these requests. In fact, defendant’s extensive business records fail to show that plaintiffs ever received a copy of the LifePlus Credit Insurance for Chase Cardmembers insurance policy or a certificate of insurance. Moreover, defendant’s records fail to show that any of the premiums collected by defendant were forwarded to any insurance company.

Defendant did not or could not produce any insurance policy or certificate of insurance for either itself or the plaintiffs in connection with these accounts. Defendant’s denial of coverage was never communicated in writing to plaintiffs.

Plaintiffs put in evidence an advertisement and solicitation for the LifePlus Credit Insurance for Chase Cardmembers that they had received from the defendant. The LifePlus Credit Insurance for Chase Cardmembers advertisement and solicitation is printed on the return payment envelope included with the monthly statements for each credit card. This document was received by plaintiffs from the defendant. The application for insurance is printed on each accounts billing statement and, upon completion is returned to the defendant. The Chase name and logo appear prominently in at least three locations on the advertisement and solicitation.

Mr. Riley testified that unemployment coverage was not offered in 1989 when the plaintiffs first purchased the policy. De[392]*392fendant did not produce any advertisement, solicitation, application, insurance policy or certificate of insurance from 1989, or any other date, showing this to be the case. Mr. Riley also testified that the unemployment coverage was not offered until January 1, 1993 and then only to new applicants. The sole evidence offered in support of this claim is Mr. Riley’s testimony. It is worthwhile to note that Mr. Riley testified that the cost of the insurance package with unemployment coverage and the cost of the package without unemployment coverage was the same.

Mr. Riley testified that Chase does not send out any annual bills or statements in connection with the LifePlus Credit Insurance for Chase Cardmembers, summary of cardmembers insurance coverage, or coverage options offered or available. In fact, it appears that the only communication concerning this insurance Chase had with the plaintiffs was the advertisements, solicitations and applications for insurance included with the regular monthly billing, and the monthly charges on the credit card accounts assessed for the insurance products.

The printed statements contained in defendant’s advertisement and solicitation submitted by plaintiffs contradict Mr. Riley’s testimony. The advertisement and solicitation for enrollment in the LifePlus Credit Insurance for Chase Cardmembers plan, which includes unemployment credit insurance, states, “If you have previously checked this box, there is no need to re-enroll. Your account is covered” (Emphasis added.)

It is worthwhile to note that the application for insurance is a part of the monthly billing statement and is returned to Chase with the monthly billing statement and payment. The advertisement and solicitation states: “[!.] Find the LifePlus Enrollment Box on this month’s billing statement when you pay your bill. [2.] Check the box to enroll in LifePlus Protection. [3.] Put your birth date on the statement in the boxes provided. Mail with your payment.” (Emphasis added.)

Mr. Riley testified that Chase would routinely refer card-members by form letter to contact the insurance company with any questions or problems. Despite the bank’s extensive records, he showed no record that this had been done in connection with plaintiffs’ claim for insurance information. The Life-Plus Credit Insurance for Chase Cardmembers solicitation states: “This credit benefit activates only when Chase is notified to do so by you.” (Emphasis added.)

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Bluebook (online)
175 Misc. 2d 389, 669 N.Y.S.2d 117, 1996 N.Y. Misc. LEXIS 595, Counsel Stack Legal Research, https://law.counselstack.com/opinion/card-v-chase-manhattan-bank-nycivct-1996.