Dwelling House Ins. v. Webster

4 Ohio Cir. Dec. 704, 7 Ohio C.C. 511
CourtAshtabula Circuit Court
DecidedNovember 15, 1893
StatusPublished

This text of 4 Ohio Cir. Dec. 704 (Dwelling House Ins. v. Webster) is published on Counsel Stack Legal Research, covering Ashtabula Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dwelling House Ins. v. Webster, 4 Ohio Cir. Dec. 704, 7 Ohio C.C. 511 (Ohio Super. Ct. 1893).

Opinions

LAUBIE, J

This is a proceeding in error to reverse the judgment of the court of common pleas, in an action brought by Julia L. Webster and James E. Webster, her husband, upon a policy of insurance, issued to 'them by the plaintiff in error, the Dwelling House Ins. Co., insuring -their dwelling-house in the sum of $2000, and personal property in .the dwelling-house to the amount of $250.-

The petition in the original action contains the ordinary and usual allegations in a suit upon a fire policy, for a total loss, with additional allegations in respect to matters that were ■claimed to constitute a waiver of “proofs of loss.”

The insurance company, in its answer, set up three defenses, each separately, as a bar to a recovery. One, that the parties plaintiffs had represented that they were the joint owners of the dwelling-house and property insured, that their representations to that effect were not true, and that by the terms of the policy, which were set out in full, such representations a.s to ownership were to be considered a.warranty, and if false, make the policy void. That in fact the real estate was the sole property of Julia L. Webster, and that the husband was the sole owner of the personal property; but intentional fraud on the part of the plaintiffs was not alleged.

Secondly, that there was a mortgage incumbrance to one Phillips, of $800, placed upon the property after the policy was issued, without any notice to the company, or consent of [705]*705the company to it, and that, by the terms-of the policy, it rendered the policy void, the policy providing, in substance, that any incumbrance thereafter placed upon the property, or any change made in the title, without notice to thq company, and consent thereto by it in writing, should avoid the policy; but there was no allegation that the risk was thereby increased.

The third defense was, that there was no proof of loss, or perhaps no truthful proof of loss, furnished by the plaintiffs to the defendant company, after the fire, as the policy required.

In their reply plaintiffs admitted that Mrs. Webster had the legal title to, and was the sole owner of the dwelling-house, and that Mr. Webster was the sole owner of the personal property, but denied the misrepresentations alleged, and averred that the true state of the title was made known to the agent of the company at the time of the application for the policy; and further averred, that if the misrepresentations were made as claimed, they constituted no defense to the action, because of the provisions of sections 3643, 3644, Rev. Stat., asno intentional fraud was charged. They denied that they had subsequently incumbered the real estate by mortgage, without the knowledge and consent of the company; averred such knowledge and consent; and, further, if there were no such knowledge and consent, it constituted no defense, because of the provisions of the sections aforesaid, as it was not charged that the risk had been thereby increased.

In reference ,to two matters, we may at the outset dispose of them in a few . words, so that they need not be referred to 'hereafter. One is in reference to the personal property, which belonged solely to the 'husband. The plaintiffs abandoned this part of the case, and did not ask for any recovery under the policy for the loss of the personal property.

Secondly, as to the third defense, the failure to furnish proof of loss. There is no allegation- in the answer what the effect of that failure would be,' according to the terms of the policy. It simply alleges that such proof of loss as is therein stated was to be -rendered, but the effect of the failure to render it, is not alleged. The case was argued upon the proposition that by the terms of the policy a failure to furnish proof of 1-oss as therein stated, would render the policy void; but as there is no such allegation in the answer, we may dismiss that from consideration, and it leaves to be considered only .the two other defenses.

The bill of exceptions does not attempt to set out all of the evidence. It states merely that evidence was given by each party, tending to prove the issues upon their part. That the plaintiffs introduced evidence tending to prove the allegations of their petition; that the defendant introduced evidence tending to establish the allegations and statements of its answer, and that the plaintiffs in reply introduced evidence tending to sustain the allegations of t'heir reply. So we have to look at the case as if there was testimony upon all the points involved in the controversy, and tending to prove all -the allegations of the defendant’s answer.

It appears by the bill of exceptions that the defendant’s counsel asked the court to charge the jury this proposition:

“If the plaintiff, after the issuing of the policy sued upon, and b.efore the loss, placed a mortgage lien upon the real estate upon which the house burned was situated, without notice to the company, or its consent to such incumbrance, such action on the part of the plaintiff was in violation of the terms of the policy, and rendered the policy void, and the plaintiffs, if the jury find the facts as above stated, cannot recover in this action.”

This -the court refused to give, to which the defendant excepted.

The charge' -on the questions here made, wa.-s as follows:

“Gentlemen oe the Jury as you have already observed by the language which ds used in the statute, there are substantially two defenses provided for by law, where a policy is issued and paid for upon a building and there is a total destruction of the building. The one is intentional fraud on the part of the insured, which would be the plaintiffs in this case, in procuring the policy to be issued; but as we have said to you, no fraud is charged, and therefore you need not consider it further, as it does not come within the issues of this case.
“The other we desire to call your special attention to. As we have said to you, in the absence of any change -increasing the risk, without the consent of the insurer, and also of intentional fraud_ on the part of the insured, in case of total loss, the whole amount mentioned in the policy or renewal upon which the insurers received a premium, shall be paid.
“The defendants allege that there was a change made by the plaintiffs in regard to the condition of this property, and they say, or claim, that it increased the risk, although that [706]*706is not alleged in the answer, and we say to you, gentlemen of the jury, as matter of law, that although you should find that subsequent to the issuing of the policy and before the fire, a mortgage was executed to Phillips, that does not of itself constitute a defense in this action. It only constitutes a defense under the statute, when the jury find that such mortgage increased the risk, or the hazard, or increased the liability of the insurance company to loss, and made it more hazardous for them.

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Bluebook (online)
4 Ohio Cir. Dec. 704, 7 Ohio C.C. 511, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dwelling-house-ins-v-webster-ohcirctashtabul-1893.