Frank Lucas Insurance Agency, Inc. v. Fireman's Fund American Insurance

425 A.2d 1378, 48 Md. App. 122, 1981 Md. App. LEXIS 221
CourtCourt of Special Appeals of Maryland
DecidedMarch 5, 1981
Docket616, September Term, 1980
StatusPublished
Cited by1 cases

This text of 425 A.2d 1378 (Frank Lucas Insurance Agency, Inc. v. Fireman's Fund American Insurance) is published on Counsel Stack Legal Research, covering Court of Special Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Frank Lucas Insurance Agency, Inc. v. Fireman's Fund American Insurance, 425 A.2d 1378, 48 Md. App. 122, 1981 Md. App. LEXIS 221 (Md. Ct. App. 1981).

Opinion

Thompson, J.,

delivered the opinion of the Court.

On January 1, 1974, Frank Lucas Insurance Agency, Inc. and Lucas Insurance, Inc., appellants, entered into separate Agency Agreements with Fireman’s Fund American Insurance, et al., appellees. Due to unfavorable loss ratios, the appellees terminated the agreements effective December 1, 1978, pursuant to the termination provisions of the agreements. The appellants filed separate complaints with the Insurance Commissioner contesting the cancellations. The Commissioner found no violation of any statute in the cancellation of the agency agreements. The appellants appeal to the Baltimore City Court, which affirmed the Commissioner’s decision. The validity of the terminations is not at issue in the current proceedings. As required under Md. Ann. Code Art. 48A, § 234B (c), appellees renewed, through the appellants, policies which expired between December 1, 1978 and December 1, 1979. The present dispute arose with respect to renewals of policies made after December 1, 1979.

*124 In the fall of 1979, appellees notified the appellants that they intended to send to the policyholders whose business had been written through the appellants a letter advising them of their rights with respect to renewal. The appellees contend this letter was designed to comply with Maryland statutes. The proposed letter read as follows:

"As your agent no longer represents the Fireman’s Fund Insurance Companies, the above captioned policy will not be renewed through that agency.
"We suggest that you contact your agent to seek replacement of coverage with another Insurer upon expiration of your policy.
"Maryland Statute states that no Insurer shall cancel or refuse to renew the policy of an Insured because of the termination of the agent’s or broker’s contract. You, therefore, have the option to continue your coverage with the Fireman’s Fund Insurance Companies by contacting another agency which represents us; or if you desire, we can issue coverage on a direct basis from our office.
"If we do not hear from you prior to the expiration date of the policy, we will assume you have replaced your coverage with another Insurer.”

The appellants objected to the letter being mailed to their customers and claimed that the agency agreements entitled them to commissions on policies originally placed by them and renewed by the appellants after December 1, 1979. These issues were argued before Assistant Insurance Commissioner Thomas Paul Raimondi, who held in favor of appellants. The appellees appealed to the Baltimore City Court. The court reversed the order of the Insurance Commissioner. It held that neither appellant was entitled to commissions on policies renewed after December 1,1979 and that appellees could send the proposed letter of notification to the policyholders.

Appellant, Frank Lucas Insurance Agency, Inc., now appeals from the holding that neither the Agency *125 Agreement nor the Limited Agency Agreement 1 entitle it to commissions on renewals effected pursuant to Md. Ann. Code Art. 48A, § 234A, i.e., occurring after December 1, 1979. Appellant, Lucas Insurance, Inc., appeals from the holding that the Agency Agreement does not entitle it to commissions on renewals effected pursuant to Art. 48A, § 234A and that the appellees are permitted to mail the notice letter to the policyholders. The appellants raise the following two questions: (1) Whether appellants are entitled to payment of commissions on policies produced by appellants prior to termination of the Agency Contracts but continued or renewed by appellees as required by statute; and (2) whether the letter which appellees undertook to send to policyholders is in violation of the Agency Contracts and misleading.

Before we undertake to discuss the questions presented we think it well to quote from the statute as to the standard of review for determinations made by the Insurance Commissioner. These standards are set out in Md. Ann. Code Art. 48A, § 40 (5):

"(5) Judgment. — The court may affirm the decision of the Commissioner or remand the case for further proceedings; or it may reverse or modify the decision if the substantial rights of the petitioners may have been prejudiced because the administrative findings, inferences, conclusions, or decisions are:
(i) In violation of constitutional provisions; or
(ii) In excess of the statutory authority or jurisdiction of the Commissioner; or
(iii) Made upon unlawful procedure; or
(iv) Affected by other error of law; or
(v) Unsupported by competent, material, and substantial evidence in view of the entire record as submitted; or
*126 (vi) Against the weight of competent, material and substantial evidence in view of the entire record, as submitted by the Commissioner and including de novo evidence taken in open court; or
(vii) Unsupported by the entire record, as submitted by the Commissioner and including de novo evidence taken in open court; or
(viii) Arbitrary or capricious.”

Md. Ann. Code Art. 48A, §§ 234A and 234B prohibit an insurance company from cancelling or refusing to renew a policy for reasons which are not reasonably related to the insurer’s economic and business purposes and specifically prohibit the refusal to renew because of the termination of the agent’s contract. 2 The trial court found that the appellants’ rights to commissions on the policies here in question were governed by the following section of the Agency agreements:

*127 "III. COMMISSIONS
(5) Agent shall have a vested interest in such commissions as are payable on contracts of insurance which contain a guaranty of renewal or which are continued by order of governmental authority, except where Agent is replaced as agent of record.”

It made a finding, which has not been disputed here, that none of the contracts contained a guaranty of renewal and that the question was therefore to be resolved by determining the meaning of the words "which are continued by order of governmental authority, except where the Agent is replaced as agent of record.” It found that the policies in question were neither "continued” nor were "by order of governmental authority” and that the Agent "was replaced as agent of record.” We disagree with each of these three findings. In making his ruling as to the meaning of the word "continue” the trial judge stated:

"I think that the closest call, if you will, among these three criteria involves the word 'continue.’ What is a policy which is continued? Even though it is a close question, it is the feeling of this Court that it is not synonymous with renewal.

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Related

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441 A.2d 1098 (Court of Special Appeals of Maryland, 1982)

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Bluebook (online)
425 A.2d 1378, 48 Md. App. 122, 1981 Md. App. LEXIS 221, Counsel Stack Legal Research, https://law.counselstack.com/opinion/frank-lucas-insurance-agency-inc-v-firemans-fund-american-insurance-mdctspecapp-1981.