Hogg v. Phoenix Insurance

1 Balt. C. Rep. 516
CourtBaltimore City Superior Court
DecidedMarch 30, 1895
StatusPublished

This text of 1 Balt. C. Rep. 516 (Hogg v. Phoenix Insurance) is published on Counsel Stack Legal Research, covering Baltimore City Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hogg v. Phoenix Insurance, 1 Balt. C. Rep. 516 (Md. Super. Ct. 1895).

Opinion

RITCHIE, J.

Opinion of Judge Ritchie on the prayers in the above entitled cause.

First as to the right of the plaintiff to maintain this suit.

If it is provided in a policy of insurance, either in express terms or by necessary implication, that in case of a disagreement as to the loss, there shall be an appraisement, and that no loss will be payable, and no suit will lie until an award has been made, then appraisal and award constitute a condition precedent to the institution of any suit. But such a condition ought to appear in express terms, or by clear implication. It is claimed, with great force of argument by the defendant, that there is in this policy such a condition precedent, and that this suit has been prematurely brought. But for a well established rule of construction, expressly recognized by the Supreme Court in 95 U. S., that the policy, having been prepared by the defendant itself, must, in case of ambiguity, be construed most strongly against the company, there would be some difficulty in answering the argument made on behalf of the defendant. In construing this policy, the circumstances under which this question is raise'd may properly be referred to. This fire occurred on September 5th, 1892; notice was given on the 6th, proofs of loss were duly submitted, plans and specifications of the building were furnished to the company at the request of its adjuster, and also the certificate of a neighboring magistrate, in pursuance of a similar request. The defendant’s adjuster then demanded plans and specifications of the building as it existed imvmediately before the fire, and also a book in possession of a certain Preston, and a paper in the hands of Mr. Trippe, said to contain a long list of defects in the building and in its construction as of the time of the fire. On failure of plaintiff to comply with these further demands, the adjuster seems to have suspended all action on his part toward making our his estimate of the loss, and up to the time of instituting suit in June, 1893, the company, while objecting to the plaintiff’s estimate of his loss had not submitted any estimate of its own, nor had there been any demand on its part for an appraisement of the loss, nor any refusal by plaintiff to submit to one.

The condition of appraisement always rests on a precedent disagreement. Whether objection to the plaintiff’s valuation without any estimate on the part of the company (to which it is possible the plaintiff may have [517]*517agreed) completes the disagreement; and if not, what effect the inactivity of the defendant for six months after proofs submitted, and its failure to do what was necessary on its part to bring about the disagreement, would have on the provision for appraisement, as a waiver, need not be passed on. However this may be, this policy provides that no suit shall be sustainable unless brought within twelve months after the fire, and if this suit must be dismissed as prematurely brought, the practical result would be precisely the same as if the Court were to declare a forfeiture of the policy, because, in view of the fact that the period of limitation has expired, it would not be possible for the plaintiff to sustain another suit. While these facts cannot affect the question whether the policy contains this condition precedent, or not, I think they may properly remind the Court of the importance of enforcing the rule of strict construction as against the defendant — the rule that if this policy is equivocal or ambiguous in its terms, its construction must be such as is most favorable to the insured. When I come to look at the terms of this policy I do not find, either in express terms, or by necessary implication, under the rule of construction by which I am controlled, the condition precedent which has been insisted upon. It is a policy to insure the plaintiff against direct loss from fire to this dwelling; such loss to be measured by the actual cash value of the property at the time it was destroyed. It provides that it shall be ascertained by agreement between the parties, or if they disagree there shall be an appraisement, but I do not find, on considering the whole policy, that such appraisement, in case of disagreement, is absolutely a condition precedent to the institution of a suit. I think I may properly say here that if an insurance company intends to insert in its policy such a condition, it ought to be done plainly and in express terms, and in such a way as that the insured may readily apprehend it. 1 do not think that a. condition of this kind ought to be inserted in such a way as that it cannot be found except by taking this, that, and the other provisions of the policy, and then, by putting them together, thus develop a condition precedent by construction. If, however, such condition is in this policy, I must so construe it, whether it is plainly expressed, or whether it is to be found in such implications as 1hat only a professional mind would be likely to detect it. But, as I have said, this policy, in my judgment, is equivocal and ambiguous on the point in quesiion.

The defendant claims that this condition is to be found by taking together the provision already mentioned as to appraisement, the provision as to payment of loss, beginning at the ninety-third line, and the provision as to bringing suit, beginning at line 106. The provision as to payment is viz: “And the loss shall not become payable until sixty days after the notice, ascertainment, estimate and satisfactory proof of the loss herein required have been received by this company, including an award by appraisers when appraisal has been required.” Here, to my mind, is a clear case of ambiguity. “Required” by whom? “Required” by what? It is argued by the defendant that this means, required by the exigency, required by the preceding provisions of the policy. Very well, that is one construction, and a reasonable one from the standpoint of the company ; but, at the same time, T think that any one reading this provision, would naturally fill up the uncompleted sentence, “when appraisal has been required,” by adding the words by either party. It is clearly capable, I think, of this latter construction just as well as it is of the other — and if the latter construction be correct, then, by implication, the appraisement must first be called for by one, of the parties. The policy being equivocal, it is to receive the construction most favorable to the party insured.

Coming now to the provision as to bringing suit. It does not provide that no suit shall be sustainable until an award has first been had. It reads as follows: “No suit or action on this policy, for the recovery of any claim, shall be sustainable in any Court of law or equity until after full compliance by the insured with all the foregoing requirements.” It is by coupling this provision with the others alluded to, that the defendant claims to work out a condition of precedent. But this does not make an award a condition precedent. In requiring full compli[518]*518anee by the insured with aforegoing requirements, this policy cannot be taken to require of him compliance with requirements, the fulfilment of which does not rest personally and entirely upon him. He must first give notice, furnish proofs, comply with proper demands, etc., but appraisement, or the appointment of two appraisers, could not be the subject of a requirement resting individually and entirely upon him. No appraisement could be had without the joint action of both.

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Bluebook (online)
1 Balt. C. Rep. 516, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hogg-v-phoenix-insurance-mdsuperctbalt-1895.