Hinds v. United Insurance Co. of America

149 S.E.2d 771, 248 S.C. 285
CourtSupreme Court of South Carolina
DecidedJune 27, 1966
Docket18540
StatusPublished
Cited by15 cases

This text of 149 S.E.2d 771 (Hinds v. United Insurance Co. of America) is published on Counsel Stack Legal Research, covering Supreme Court of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hinds v. United Insurance Co. of America, 149 S.E.2d 771, 248 S.C. 285 (S.C. 1966).

Opinions

Bussey, Justice.

In this action ex delicto, the plaintiff-respondent seeks to recover damages from the defendant-appellant resulting from the alleged negligence of appellant in the handling of applica[288]*288tion by respondent for insurance. The appeal is from an order of the lower court overruling appellant’s demurrer to, and refusing a motion to strike certain portions of the complaint.

Summarized, the facts stated in the complaint are as follows. About January 1961, appellant solicited and obtained from respondent an application for a policy of health and accident insurance which was issued. Thereafter, about December 1, 1961, appellant solicited respondent’s application for a more comprehensive policy, which included a retirement provision, to replace the policy first issued. Upon the issuance of this second policy, the first was canceled. Thereafter, respondent discovered that the second policy was actually not in accordance with his understanding thereof at the time he applied for it, and after making two or three quarterly payments thereon, he allowed this second 'policy to lapse some time during the year 1962. In either December 1962 or January 1963, appellant’s agent advised that respondent could reinstate the policy first issued if he did so before March 15, 1963, it being alleged that the agent knew or should have known that such statement was not true. The said agent subsequently, on February 19, 1963, took respondent’s application for reinstatement of the first policy, together with respondent’s check in the amount of $40.50, in payment of the first quarterly premium on the policy to be reinstated. Respondent assumed that such policy had been reinstated, until July 23, 1963, when he was advised by another of appellant’s agents that the time for reinstatement had expired prior to the application on February 19, 1963, and that respondent would have to apply for a new policy and pay an additional premium. On that date, July 23, 1963, respondent applied for the new policy, gave to the agent an additional check in the amount of $12.50, which check, together with the February check in the amount of $40.50, was cashed by the appellant on July 31, 1963. The new policy applied for was not issued, however, until September 25, 1963, and that policy con[289]*289tained a provision excluding coverage for any heart attack occurring within six months after the issuance thereof. On March 20, 1964, the respondent suffered a heart attack for which he would have received benefits, but for the fact that such attack occurred five days before the new policy had been in effect for six months. It is further alleged that the respondent would have had coverage at the time of his heart attack but for the negligent, reckless, willful and wanton acts on the part of the appellant and its agents in misleading respondent into believing that the original policy could be reinstated and that it had been reinstated; and in failing to accept or reject his application for reinstatement, as well as his application of July 23, 1963, within a reasonable time. Both actual and punitive damages in the amount of $10,000 were prayed for.

The exceptions of the appellant are several. There is considerable overlap between appellant’s arguments in support of its demurrer and its arguments in support of its motion to strike, and for this reason we shall not attempt to deal with them separately, but will endeavor to dispose of all the questions raised.

What we deem to be the primary contention of the appellant, is its assertion that the facts alleged do not give rise to a cause of action ex delicto. No case directly in point on the facts has been cited or come to our attention. In principle, however, we do not see where the instant case can be soundly distinguished from the case of Tobacco Redrying Corp. v. United States Fidelity & Guaranty Co., 185 S. C. 162, 193 S. E. 426. In that case the insurer was held liable for the negligence of its agent in failing to forward an application to the company. The applicant for insurance was allowed to recover for a loss sustained by it, as to which it was not covered, and as to which it would have been covered, but for the negligence of the agent. It is, of course, true that a policy was eventually issued in the instant case, whereas no policy was issued in the cited case, but the cases are idential in that under the allegations of the complaint [290]*290in. the instant case the respondent sustained a loss, as to which he had no coverage, and as to which he would have had coverage but for the negligent, willful and wanton conduct of the appellant. It is thus apparent that the grave-men of respondent’s complaint is the same as the gravamen of the complaint in the cited case.

As pointed out by the appellant, the decisions from other jurisdictions are not unanimous on the question of whether an insurer may be liable in tort for damages resulting from negligent delay in acting upon an application for insurance. See 29 Am. Jur. 593, Insurance, Sec. 204; 15 A. L. R. 1029; 75 A. L. R. 955; 32 A. L. R. (2d) 511. The cited annotations will reflect that other jurisdictions are approximately evenly divided on the question, but we think that the better reasoned decisions are in complete accord with the rationale of our own decision in Tobacco Redrying Corp. v. United States Fidelity & Guaranty Co., supra.

While various reasons have been advanced for either allowing or denying a recovery, one of the principal reasons advanced in support of the allowance of a recovery is the fact that, as stated by Appleman in Insurance Law and Practice, Vol. 12, Sec. 7226.

“The business of insurance is affected by public interest, the insurer being bound to furnish the indemnity which the state has authorized it to issue, or to decline to do so within such a reasonable time as will enable the applicant to act intelligently upon rejection. * * *

“The more liberal, and probably the better rule, is to the effect that an insurance company obtaining an application for insurance is under a duty to accept it or reject it within a reasonable time, and is liable if it delays unreasonably in acting thereon.”

The jurisdictions which deny recovery for negligence with respect to an application would appear to either' not recognize, or else not give effect to, the principle that the insurance business is affected with a public interest. [291]*291In this jurisdiction it has long been recognized that insurance is a business affected with a public interest. See La Tourette v. McMaster, 104 S. C. 501, 89 S. E. 398. In the opinion in that case the court, speaking of insurance agents and brokers, said,

“It is important for the protection of the interests of the people of the state that the business should be in the hands of competent and trustworthy persons. * * * Moreover, they are required to exercise due care in placing insurance, and would be personally liable for the neglect of that duty.”

While not dealing with the precise controversy we have here, a number of our decisions have recognized the duty owed by an insurer and its agents to an applicant to avoid representations which would mislead the applicant to his detriment, and at the same time handle the application with care and without unreasonable delay. See Ward v. Liberty Life Ins. Co., 232 S. C. 582, 103 S. E. (2d) 48; Keller v. Provident Life and Accident Ins. Co., 213 S. C. 339, 49 S. E. (2d) 577. In the last cited case it was said,

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Hinds v. United Insurance Co. of America
149 S.E.2d 771 (Supreme Court of South Carolina, 1966)

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Bluebook (online)
149 S.E.2d 771, 248 S.C. 285, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hinds-v-united-insurance-co-of-america-sc-1966.