Gates v. Nationwide Mutual Insurance

34 Pa. D. & C.2d 471, 1964 Pa. Dist. & Cnty. Dec. LEXIS 131
CourtPennsylvania Court of Common Pleas, Mercer County
DecidedJuly 1, 1964
DocketNo. 2
StatusPublished

This text of 34 Pa. D. & C.2d 471 (Gates v. Nationwide Mutual Insurance) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Mercer County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gates v. Nationwide Mutual Insurance, 34 Pa. D. & C.2d 471, 1964 Pa. Dist. & Cnty. Dec. LEXIS 131 (Pa. Super. Ct. 1964).

Opinion

McKay, J.,

In this action of assump-sit on an insurance policy, defendant has moved for a [472]*472new trial and for judgment n. o. v. following a verdict in favor of plaintiff. In the present motions it is the position of defendant that we erroneously submitted two issues to the jury and that without the findings of the jury thereon there was not enough evidence to support the verdict. The relevant facts will be stated under each of the issues questioned.

I. The Oral Notice of Assignment of Interest

On March 18, 1958, Jack J. Gates and Mickey McVeigh were partners engaged in a food business at 1839 Elm Street, N.E., Warren, Ohio, known as the Golden Dawn Supermarket. On that date, defendant company issued to them a policy of insurance, insuring them against loss by theft or disappearance of funds in their business. The issuing agent of defendant was John Bachrik, Gate’s brother-in-law. The policy provided in part as follows:

“12. CHANGES: Notice to any agent or knowledge possessed by any agent or by any other person shall not effect a waiver or a change in any part of this policy or estop the Company from asserting any right under the terms of this policy; nor shall the terms of this policy be waived or changed, except by endorsement issued to form a part of the policy; signed by the President, Vice President or Secretary, and countersigned by a duly authorized representative of the Company.”
“15. ASSIGNMENTS: Assignment of interest under this policy shall not bind the Company until its consent is endorsed hereon; if, however, the Insured shall die, this policy shall cover the Insured’s legal representative as Insured; provided that notice of cancellation addressed to the Insured named in the declarations and mailed to the address shown on this policy shall be sufficient notice to effect cancellation of this policy.”

In January, 1959, the partners, being in financial straits, incorporated their business under the name of Gates and McVeigh, Inc. The partners were the sole [473]*473stockholders except for a wholesale grocery company, Golden Dawn Foods, to which they were indebted and which took stock in the new corporation to protect its indebtedness. Shortly after the incorporation had been effected Gates informed Bachrik, from whom they had purchased the policy, of that fact and Bachrik told Gates that he would “take care of” changing the name on the policy to the corporate name. Thereafter the partners, relying upon Bachrik’s statement, did nothing further. In particular, they did not see to it that a written assignment of interest endorsement was obtained from the company, and attached to the policy which was in their possession.

On January 23,1962, $4,414.73 was abstracted from the corporation. When a claim for the loss was presented to defendant, it refused to honor it, claiming that the partners were not entitled to be reimbursed because it was the corporation that had suffered the loss and that the corporation would not be paid because it was not the assured named in the policy. The company did not question that the loss had been sustained.

The suit was originally brought in the name of the partners as plaintiffs, but later the complaint was amended to assert, in the alternative, that the corporation was entitled to recover for the loss. We directed a verdict for defendant in the suit of the partners but submitted the suit of the corporation to the jury.

In addition to the facts recited above, plaintiffs’ evidence also showed that Bachrik’s name appeared in writing on the policy above the words “Authorized Agent”; and that the corporation paid the annual premiums on the policy from 1958 to 1963 with corporation funds by checks on which the name of the corporation was printed. On the other hand, Bachrik, testifying for defendant, said that he had no authority to waive any of the provisions of the policy. We submitted to the jury the question whether, under all of the evi[474]*474dence, Bachrik had authority to waive the requirement of the policy that the assignment of interest be noted on the policy by written endorsement and whether by telling Gates that he would “take care of” the matter, i.e., seeing to it that the assignment and consent were attached to the policy, Bachrik waived the requirement.

The policy was made and was intended to be performed in Ohio. Hence the law of that State governs in its construction.

Under the law of Ohio, a provision of an insurance policy relative to the assignment of interest therein may be waived by a duly authorized agent of the company: 30 Ohio Juris 2d, §782.

Even a provision that a waiver must be in writing may itself be waived by accepting an oral notice, provided the agent has the requisite authority: Ohio Farmers Ins. Co. vs. Cochran, 104 Ohio 427, 135 N. E. 537.

In the present case, there can be no doubt that there was ample evidence from which the jury was warranted in finding that Bachrik orally waived the policy requirement that the assignment of interest of the partnership to the corporation be evidenced only by a written endorsement.

The only serious question is whether Bachrik had authority to waive the requirement.

Again referring to the law of Ohio, we note that The Revised Code of Ohio, §3929.27 provides,

“A person who solicits insurance and procures the application therefor shall be considered as the agent of the . . . company . . . thereafter issuing a policy upon such application or a renewal thereof, despite any contrary provisions in the policy . . .”

Construing this clause, the Ohio Court of Appeals in the Case of Hall vs. Franklin Fire Insurance Company of Philadelphia, 149 Ohio 216, 78 N. E. 2d 360 (1948), held that the statute applied to the assignment of a fire policy.

[475]*475In that case, the owner of the insured premises conveyed them to his brother and reported the transaction to the fire insurance agent of defendant company, whereupon the agent told the brother assignee that the latter was covered by the fire insurance as to the property so transferred, although the agent failed to endorse the assignment on the policy and notify defendant company thereof. The policy provided inter alia that it would be void if assigned unless the agreement was endorsed on the policy and again that the policy “unless otherwise provided by agreement endorsed hereon or added hereto, shall be void... if any change . . . take place in the interest, title or possession of the subject of insurance . . .” The court, at page 365, referred to the provisions of section 9586 of the General Code, reenacted in the Revised Code, quoted above, and stated that “the assignment of a policy of fire insurance to a new owner of the property covered does not differ in principle from the solicitation of a new policy on the same property.” The court then held that since the agent had full authority to issue a new policy, there was no difference between the assignment of the policy and the issuance of a new one and hence that the agent who had full power to issue a new policy was equally authorized to consent to the assignment of interest without first communicating with defendant.

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Bluebook (online)
34 Pa. D. & C.2d 471, 1964 Pa. Dist. & Cnty. Dec. LEXIS 131, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gates-v-nationwide-mutual-insurance-pactcomplmercer-1964.