Faustman v. Commerce Insurance

12 Mass. L. Rptr. 264
CourtMassachusetts Superior Court
DecidedJuly 5, 2000
DocketNo. 992303
StatusPublished
Cited by1 cases

This text of 12 Mass. L. Rptr. 264 (Faustman v. Commerce Insurance) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Faustman v. Commerce Insurance, 12 Mass. L. Rptr. 264 (Mass. Ct. App. 2000).

Opinion

Sosman, J.

Plaintiff Denise Faustman has brought the present action seeking to recover on her homeowner’s insurance policy for alleged theft losses at her home. Defendant Commerce Insurance Company has moved for summary judgment on the ground that the suit is time-barred by the terms of the policy and by G.L.c. 175, §99. For the following reasons, the motion is ALLOWED.

Facts

Commerce Insurance Company issued a homeowners insurance policy to plaintiff Denise Faustman and her former husband, James Breitmeyer, for the premises located at 74 Pinecroft Road in Weston. The perils insured against included loss due to fire and loss of personal property by means of theft. Under an endorsement entitled “Special Provisions — Massachusetts,” the policy provided that no action could be brought against Commerce unless “the action is started within two years after the date of loss or damage occurs.”

Beginning at some point in the fall of 1996 and continuing up until March 20, 1997, a nanny employed in Faustman’s home stole cash and personal property belonging to Faustman and her former husband. Faustman is not aware of any thefts occurring later than March 20, 1997. The nanny was ultimately convicted in connection with these thefts.

Faustman notified Commerce of these losses in March 1998, after the conclusion of the criminal proceedings against the nanny. Commerce conducted its investigation, including an examination of Faust-man under oath on August 18, 1998. By letter dated January 5, 1999, Commerce’s attorney notified Faust-man that her claim was being denied in its entirety.

On January 18, 1999, Faustman’s attorney sent Commerce a demand letter pursuant to G.L.c. 93A, claiming various violations of G.L.c. 176D. On February 1, 1999, Commerce’s attorney responded to that demand letter. The present action for breach of the insurance contract and violation of G.L.c. 93A was filed on May 6, 1999.

Discussion

Commerce contends that the present action is time-barred, as the date of filing (May 6, 1999) is more than two years after the last of the thefts at issue (March 20, 1997). Commerce relies on the policy provision requiring suit to be brought within two years of the date of loss, and further argues that that two-year time period is the one prescribed for such a policy by G.L.c. 175, §99. The statute sets requirements of various items that must be included in policies “that insure against loss or damage by fire or by fire and lightning to property or interests in the commonwealth.” Among the requirements set by §99 is inclusion of the following language: “No suit or action against this company for the recovery of any claim by virtue of this policy shall be sustained in any court of law or equity in this commonwealth unless commenced within two years from the time the loss occurred.” Commerce contends that this homeowners policy, which included insurance against loss by fire, therefore included the required two years from date of loss time limit for bringing any claim based on the policy.

However, Faustman points to a contrary statutory provision in G.L.c. 175, §22, which expressly prohibits the inclusion of various specified provisions in “any policy of insurance.” Among the prohibited items is “any condition, stipulation or agreement . . . limiting the time for commencing actions against it to a period of less than two years from the time when the cause of action accrues.” The first paragraph of §22 concludes: “Any such condition, stipulation or agreement shall be void.” Because the date of loss is not the same as the date on which a cause of action against an insurer accrues, a provision allowing only two years from the “date of loss” violates the §22 requirement that the time in which to sue can not be set at anything less than two years from “the time when the action accrues.” See Barton v. The Automobile Insurance Co. of Hartford, 309 Mass. 128, 130 (1941).

The problem of reconciling the prohibition set forth in §22 with the contrary mandate set forth in §99 was addressed in Goldsmith v. Reliance Insurance Co., 353 Mass. 99 (1967). The plaintiff in Goldsmith brought an action to recover for fire loss occurring at his business, on which he had carried multiple fire insurance policies. Under the policies, the insurers were required to make payment or replace the property within sixty days of the insured’s submission of his proof of loss. Plaintiff had commenced his lawsuit more than two years from the date of the fire, but the cause of action against the insurers did not accrue until they had failed to make payment or replacement on that sixtieth day after the proof of loss had been submitted. The suit had been filed before the two year deadline from that date on which the cause of action had accrued. Plaintiff argued that §22 governed and rendered void the policy provisions that had been set in compliance with §99. The court disagreed, holding that §22 applied to any “nonstatutory limitations" but did not void any separate requirements or limitations that were “directed by the Legislature.” 353 Mass, at 102.

Faustman’s standard homeowners policy includes insurance against loss by fire, but it also insures [266]*266against a whole array of other perils (including theft) that are totally unrelated to fire. The question on this motion is whether the inclusion of fire insurance with other types of coverage makes the entire policy subject to §99, thereby avoiding the proscriptions of §22 or whether the different coverages in the policy are made subject to differing statutes of limitations. As always, this court should seek to interpret and apply these two statutes consistent with the legislature’s intent.

Issuance of such a homeowners policy is authorized by G.L.c. 175, §54E. In §54E, the legislature provided that companies who were authorized to write fire insurance and who had been “actively engaged in the fire insurance business” for at least ten years would be allowed to “insure against loss or damage to dwellings and appurtenant structures and to the contents thereof and any other personal property of a similar nature of the insured or members of his household resulting from any peril proper to insure against in this commonwealth, and may, in addition, insure against the legal liability of the insured or of members of his household arising out of non-business pursuits, and insure with respect to medical, surgical and hospital expenses.” However, “insurance against loss or damage by perils other than the peril of fire may be written only when insurance against the peril of fire is written in the same policy and on forms which have been submitted to and approved by the commissioner.” Id. In other words, the combining of fire insurance with other types of insurance in a homeowners policy is not only allowed, but the inclusion of fire insurance in such a policy is mandated by §54E. The legislature expressly allowed (and indeed required) the combining of fire insurance with the other coverages that are in Faustman’s homeowner policy.1

Where the legislature in §54E specifically treated the other perils insured against as things to be added to what were fundamentally fire insurance policies issued by companies with experience in fire insurance, it appears that the legislature intended that these policies be governed by the requirements that govern fire insurance policies, including §99, rather than the general requirements set forth in §22.

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Bluebook (online)
12 Mass. L. Rptr. 264, Counsel Stack Legal Research, https://law.counselstack.com/opinion/faustman-v-commerce-insurance-masssuperct-2000.