Frink v. River Source Life Insurance Company

CourtDistrict Court, D. Arizona
DecidedJanuary 31, 2022
Docket2:20-cv-01327
StatusUnknown

This text of Frink v. River Source Life Insurance Company (Frink v. River Source Life Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Frink v. River Source Life Insurance Company, (D. Ariz. 2022).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Amy Frink, No. CV-20-01327-PHX-DLR

10 Plaintiff, ORDER

11 v.

12 River Source Life Insurance Company,

13 Defendant. 14 15 16 Before the Court are the parties’ motions for summary judgment (Docs. 59, 60) 17 which are fully briefed. For the reasons set forth herein, Plaintiff’s motion is denied and 18 Defendant’s motion is granted in part and denied in part.1 19 I. Background 20 Plaintiff purchased a disability insurance policy (“Policy”) from Defendant on July 21 15, 2010. Thereafter, the premiums were due annually on July 15th. The Policy provided 22 an additional 31-day grace period for payment of the premium before the Policy would 23 lapse. Additionally, Defendant had internally instituted an extended grace period, which 24 automatically reinstated a lapsed policy if the premium was received within 60 days of the 25 premium due date. With Plaintiff’s Policy, the extended grace period would expire on 26 September 13th. 27 1 Oral argument is denied because the issues are adequately briefed, and oral 28 argument will not aid the Court’s decision-making. See Fed. R. Civ. P. 78(b); LRCiv. 7.2(f). 1 The Policy’s “Reinstatement” provisions provided Plaintiff six months after a lapse 2 to submit a reinstatement application along with the past-due payment. Defendant 3 thereafter would have 45 days to approve or disapprove the application: 4 If Your policy terminates because a premium is not paid by the end of the grace period You may apply to reinstate the policy 5 at any time until the first unpaid premium is 6 months overdue. 6 In order to reinstate this policy, 2 requirements must be met. They are: 7 1. You must submit a reinstatement application with evidence 8 of Your insurability and the full amount of overdue premium; and 9 2. We must approve the reinstatement application. 10 If We approve the reinstatement application, this policy will be 11 reinstated as of the date of our approval. If We do not approve or disapprove the reinstatement application within 45 days 12 from the date We receive Your reinstatement application and overdue premium, this policy will be reinstated on the 45th 13 day. 14 (Doc. 59-1 at 19.) 15 Defendant’s practice regarding payments made after the 60-day grace period, at its 16 discretion, was to automatically reinstate some policies but not others. If Defendant 17 decided to automatically reinstate a policy, it did not require a reinstatement application 18 and did not return the premium payment. On the other hand, if Defendant decided not to 19 automatically reinstate a policy, within 45 days of the late payment, Defendant would 20 return the late premium payment and request the insured to submit a reinstatement 21 application. 22 Historically, Plaintiff had been a late premium payor, never making a timely 23 payment in the 10 years she held the Policy. In 2017, Plaintiff paid 13 days after the 24 contractual grace period. In 2018, Plaintiff’s payment was made on September 6, 15 days 25 after the contractual grace period and 6 days after the extended “Due Date” as expressed 26 in the “Final Payment Notice” that year. Plaintiff’s late payments were always accepted 27 without lapse, and without explanation for the lack of enforcement of the contractual lapse 28 date. 1 In 2019, Defendant sent Plaintiff a “Payment Notification” advising her that her 2 annual premium “Due Date” was July 15, 2019. Sending a “Payment Notification” was 3 Defendant’s practice. Plaintiff failed to make her premium payment on time. The 4 contractual grace period ended on August 15, 2019. Defendant did not lapse the Policy 5 effective August 15, 2019. Instead, as was its practice, Defendant sent Plaintiff a “Final 6 Payment Notification” informing her that payment must be received by August 30, 2019, 7 or the Policy would lapse. There was no explanation why the deadline was moved to 8 August 30. However, the true deadline, according to Defendant’s internal policy, was 9 September 13, 2019. 10 Defendant received Plaintiff’s check, which was dated September 13, 2019, on 11 September 23, 2019.2 Defendant cashed the payment and held the money in “suspense,” 12 while allocating the money to Plaintiff’s account, but not applying it to the premium. 13 Defendant treated the Policy as void for non-payment after September 13, 2019. On 14 September 27, Defendant wrote Plaintiff confirming receipt of her late premium payment 15 and explaining that the payment would not be applied because the Policy had lapsed. The 16 letter instructed Plaintiff that she could apply to reinstate the Policy and that a reinstatement 17 application was required to restore her coverage under the Policy. Plaintiff disputes having 18 received the letter. 19 On October 21, Plaintiff had a stroke and was hospitalized. The next day, Plaintiff’s 20 husband spoke to Defendant’s insurance agent who informed him that the Policy had lapsed 21 and that a letter requesting a reinstatement application had been sent to her. The agent re- 22 sent the reinstatement application, but Plaintiff never submitted it. Defendant tendered 23 Plaintiff’s late premium back to Plaintiff on November 1, 2019. 24 II. Legal Standard 25 Summary judgment is appropriate when there is no genuine dispute as to any 26 2 Although Plaintiff alleges that she paid her premium on September 13, 2019, by 27 ACH transfer (Doc. 60 at 4), the record cited for that fact does not support it. The record shows Plaintiff paid by check and that it was Defendant’s practice to deposit checks the 28 date they were received. Plaintiff’s premium payment check was deposited on September 23, 2019. (Doc. 60-8 at 13.) 1 material fact and, viewing those facts in a light most favorable to the nonmoving party, the 2 movant is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(c). A fact is material 3 if it might affect the outcome of the case, and a dispute is genuine if a reasonable jury could 4 find for the nonmoving party based on the competing evidence. Anderson v. Liberty Lobby, 5 Inc., 477 U.S. 242, 248 (1986); Villiarimo v. Aloha Island Air, Inc., 281 F.3d 1054, 1061 6 (9th Cir. 2002). 7 III. Discussion 8 Plaintiff argues that Defendant’s past acceptance of premium payments after the 9 contractual grace period without terminating the Policy or requiring a reinstatement 10 application amounts to waiver or estoppel. Plaintiff further argues that Defendant’s 11 notifications of the final due dates were illusory, amounting to a waiver of strict 12 performance under the contract, because Defendant accepted late payments in the past, 13 beyond the contractual grace period, without explaining to Plaintiff its real deadline. 14 Plaintiff argues accepting late payments without explanation was waiver by conduct, and 15 that Defendant intended to relinquish its contractual right to receive premium payments by 16 31 days after July 15. 17 Waiver generally is a question of fact to be determined by the trier of fact. Jones v. 18 Cochise Cnty., 187 P.3d 97, 105 (Ariz. Ct. App. 2008). Waiver by conduct occurs when 19 the acts of an opposing party are inconsistent with an intention to assert the right in 20 question. Russo v. Barger, 366 P.3d 577, 580 (Ariz. Ct. App. 2016).

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Frink v. River Source Life Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/frink-v-river-source-life-insurance-company-azd-2022.