Dartmouth v. U.S. Life Insurance

2001 DNH 169
CourtDistrict Court, D. New Hampshire
DecidedSeptember 19, 2001
DocketCV-99-588-M
StatusPublished

This text of 2001 DNH 169 (Dartmouth v. U.S. Life Insurance) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dartmouth v. U.S. Life Insurance, 2001 DNH 169 (D.N.H. 2001).

Opinion

Dartmouth v . U.S. Life Insurance CV-99-588-M 09/19/01 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Dartmouth Hitchcock Clinic, and Hitchcock Clinic, Inc., Plaintiffs

v. Civil N o . 99-588-M Opinion N o . 2001 DNH 169 United States Life Insurance Company in the City of New York, Defendant

O R D E R

This dispute concerns an insurer’s right to cancel a group

insurance policy. Plaintiffs, Dartmouth-Hitchcock Clinic and

Hitchcock Clinic, Inc., are “participating employers” in an

insurance trust, through which they extend insurance benefits to

their employees under a group accident and health insurance

policy - policy n o . G-128,105 (the “policy”), issued by the

defendant, United States Life Insurance Company in the City of New York (“U.S. Life”). 1 Before the court are the parties’

cross-motions for summary judgment.

Background

I. General.

The University Physicians Trust (the “Trust”) was created on

July 1 , 1981, by James M. Andrew d/b/a Medical Group Financial

Services, for the purpose of holding insurance policies in trust

for the benefit of employees (and their spouses and issue) of

participating employers. The Trust agreement was amended and

restated in 1994, identifying Medical Group Financial Services,

Inc. (“MGFS”) as both settlor and trust administrator, and

Citizens Trust Company (a Rhode Island banking corporation) as

trustee. The policy was issued on July 1 , 1990, naming the

Trustee as the policyholder. See Policy at FP. Portions of the

1 Both parties attached copies of the policy to their respective motions. See Defendant’s motion for summary judgment, Ex. B ; Plaintiffs’ objection and cross-motion for summary judgment, Ex. 1 . For purposes of this order, references to the policy will cite its alpha-numerical page numbers (which correspond to specific sections of the policy).

2 policy were amended on October 1 , 1993, and again on September 1 ,

1995. See Plaintiffs’ objection and cross-motion, Ex. 1 .

Under the terms of the Trust and the policy, “participating

employers” are employers who enter into an agreement with the

settlor to participate in the Trust, thereby entitling them to

apply for insurance provided under the policy. See Defendant’s

motion for summary judgment, Ex. A , University Physicians Trust

(“Trust Agreement”); Policy at DEF-2, PE-1. The term “insured or

insured persons” refers to employees insured under the policy.

See Policy at DEF-2.

The policy describes all benefits and options available

under i t , and sets out general provisions, exclusions, and means

by which insurance coverage may be terminated. Each

participating employer’s rights under the policy are further

defined in a discrete plan of insurance (“plan”). The plan, in

conjunction with the policy, identifies the benefits and options

elected by that employer and made available to its employees.

3 The premium charged each participating employer differs depending

on coverage elections made and is set out in the respective

plans. See Policy at PLAH-1. “[U.S.] Life may change premium

rates for a Participating Employer: . . . when [the] policy is

amended; . . . when an affiliate is added to or deleted from

[the] policy; . . . [or] on the day following the Rate Guarantee

specified in the Participating Employer’s plan of insurance.”

Id. Several participating employers maintain plans under the

policy.

To summarize, then, a single, overriding policy of insurance

provides general terms, limitations, and provisions concerning

the scope, duration, and cancellation of insurance benefits.

Each participating employer’s contractual rights are further

defined in a unique “plan,” tailored specifically to that

employer’s needs. The question central to this litigation is

whether an amendment to an employer’s discrete plan necessarily

amends the terms of the overriding policy.

4 II. The Policy.

Insurance extended under the policy may terminate in several

ways, most of which are not pertinent to this case. For purposes

of this litigation, it is sufficient to note that the policy

expressly reserves U.S. Life’s “right to end [the] policy on any

policy anniversary after the first,” with sixty days advance

written notice to the policyholder. Policy at PE-1. The policy

anniversary date is July 1 .

The policy’s “General Provisions” govern changes to the

policy and unequivocally require that any changes be approved in

writing by an officer of U.S. Life, “endorsed on or attached to

[the] policy.” See Policy at GP-1. The policy also expressly

limits an agent’s authority to modify the policy, stating that

“[n]o agent may change or waive any provision of this policy.

Any change or waiver must be approved in writing by an officer of

United States Life.” See id.

5 III. Amendment of Plaintiffs’ Plan.

Throughout their participation in the Trust, plaintiffs had

no direct contact with U.S. Life. MGFS acted as a broker,

working with plaintiffs and other participating employers to

develop discrete plans of insurance under the policy, tailored to

each employer’s needs. In December of 1997, MGFS offered

plaintiffs a new premium rate “guaranteed for three years” (the

“rate guarantee”). Plaintiffs accepted the rate change on

December 1 9 , 1997, executing a “Request for Change in Plan,”

which references the policy number and provides:

Effective January 1 , 1998, the rate is renewed to $1.03 per $100 of monthly indemnity guaranteed for three years.

Premium Rate Guarantee Date Expires o n : December 3 1 , 2000.

Plaintiffs’ objection and cross-motion, Ex. 2. 2 Plaintiffs did

not solicit the rate guarantee, and apparently no policy-related

2 The quoted rate was guaranteed to The Hitchcock Clinic, Inc. Dartmouth-Hitchcock Clinic received a guaranteed rate of $1.04 per $100 of monthly indemnity.

6 discussion occurred. MGFS sent U.S. Life a fax on August 2 4 ,

1998, summarizing the renewal terms for several participating

employers, including plaintiffs’ rate guarantee. The

communication between MGFS and U.S. Life made no reference to the

specific terms of the policy.

On December 2 1 , 1998, U.S. Life notified MGFS by letter that

the policy would be cancelled on the next anniversary date (July

1 , 1999). The letter outlined how coverage issues would be

handled until the effective date of termination, and U.S. Life

informed MGFS that it was attempting to find a replacement

carrier to continue providing coverage.

Over the next several months, U.S. Life attempted to

negotiate a reinsurance agreement with Trustmark Insurance

Company (“Trustmark”), an Illinois company. Although not clearly

developed in the record, it appears that the potential agreement

with Trustmark either was not finalized, or was cancelled. In

any event, counsel for MGFS was notified in writing on October 1 ,

7 1999, that the policy termination date would be “extended one

final time to December 3 1 , 1999.” See Complaint, Ex. L.3 The

letter instructed MGFS to inform all participating groups of the

cancellation by November 1 , 1999. Plaintiffs were first notified

of the December 3 1 , 1999, termination date by letter from U.S.

Life (not MGFS) on November 2 4 , 1999. The day after plaintiffs

filed this suit, however, U.S.

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