Independent Life & Accident Insurance v. Mitchell

14 Fla. Supp. 15
CourtCircuit Court of the 7th Judicial Circuit of Florida, Volusia County
DecidedOctober 24, 1958
DocketNo. 27638
StatusPublished

This text of 14 Fla. Supp. 15 (Independent Life & Accident Insurance v. Mitchell) is published on Counsel Stack Legal Research, covering Circuit Court of the 7th Judicial Circuit of Florida, Volusia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Independent Life & Accident Insurance v. Mitchell, 14 Fla. Supp. 15 (Fla. Super. Ct. 1958).

Opinion

HORACE D. RIEGLE, Circuit Judge.

This is a case where Raymond Lee Vendler, (“Raymond” hereafter), a minor aged 19, bought two life insurance policies on November 25, 1957, #4409944-A and #4409944-B, from the Independent Life and Accident Insurance Company, on his own life, paying therefor the total initial premium of $1.01 and naming therein as the beneficiary the defendant Betty Jane Mitchell (“Betty” hereafter). Three days later Raymond was accidentally killed in an automobile accident. Thereafter Betty filed her claim for the benefits under the policies in the amount of $6,000. Orville Vendler, as Administrator of the Estate of Raymond Lee Vendler, also claimed the benefits under the policies on the ground that Betty lacked an insurable interest in the estate of the decedent, and on the further ground that the beneficiary secured the position of beneficiary by fraud and deceit. Thereupon, the insurance company duly filed its interpleader suit in this court. Interpleader was granted and the insurance company paid into the registry of the court the proceeds of the insurance policies.

The defendant Betty in her answer, claims the proceeds as the named beneficiary. The defendant Orville Vendler, as Administrator of the Estate of Raymond Lee Vendler, in his answer, claims the proceeds of the policies on two grounds — first, that the minor had no authority to name a beneficiary and that the proceeds of the insurance therefore inured to the benefit of the estate of the minor; second, that the defendant Betty, during the lifetime of the minor, claimed that the minor was the father of her child, and that she threatened him with criminal prosecution unless he married her and made her the beneficiary of these policies.

The question whether or not an infant can name a beneficiary in an insurance policy is an interesting one. Under the Pennsylvania rule referred to in 14 A.L.R. 2d, page 376, Krise v. Lycoming Trust [17]*17Company (1928), 11 Pa. D & C 411, it is held that the naming of a beneficiary is testamentary in character and since, under the Pennsylvania law, a minor cannot make a will, the naming of a beneficiary is void. However, in Florida, a minor over the age of 18 can make a will, and in this case the minor at the time of buying the insurance policies was 19 years of age, so that if we should apply the Pennsylvania rule to the facts in the case at bar we would find that the designation of Betty as beneficiary would be entirely valid under the Pennsylvania rule.

In Novosel v. Sun Life Assurance Co. of Canada, a Wyoming case cited in 55 P. 2d 302, a life insurance policy was issued on the life of a minor, naming his parents as beneficiaries, the father paying the premium. Thereafter, the minor married, and, while still a minor, changed the beneficiary to his wife. While he was still a minor, the insured died. The court held that the change of beneficiary was valid.

To the same effect is Dryman v. Liberty Life Insurance Company, 216 S.C. 177, 57 S.E. 2d 163, 14 A.L.R. 2d 371, which held—

“The insured was a minor, and the respondent takes the position, as a sustaining ground, that 'he was not competent to effect change of beneficiary in his policy of insurance.
“He had the same capacity to effect a change of beneficiary that he possessed when he first procured the policy and designated the respondent as the beneficiary. The capacity of a minor to effect a change of beneficiary in an insurance policy is recognized in the cited case of Novosel v. Sun Life Assurance Company.”

In Wainwright Trust Co. v. Prudential Life Insurance Co., 80 Ind. App. 37, 134 N.E. 913, cited in 14 A.L.R. 2d 376, it was held that the administrator of an insured who died in infancy could not avoid the designation of a beneficiary and still treat the contract of insurance as in other respects binding on the company. The court there said—

“It is averred in the complaint that appellant disaffirmed that part of the insurance contract which made Margaret Inman the beneficiary, so notified both appellees, and demanded, first, of appellee insurance company the amount due on the policy, and afterwards, when the money had been paid to the guardian, made demand of it therefor. 22 Cyc. 598, states the rule to be that: ‘A contract of life insurance is not binding on an infant, but such contract is voidable only and not void/
[18]*18“This rule is followed in this court in the case of Shroyer v. Pittenger, 31 Ind. App. 158, 67 N.E. 475, where the court says : ‘The better reasoning supports the rule that no contract of an infant is void because of his nonage, but all such contracts are voidable only.’
“In order, therefore, to avoid it, there must be a rescission. But it must be a rescission of the whole contract, and this is the effect of a disaffirmance of the voidable part of a contract. This rule is thus stated in Rice v. Boyer, 108 Ind. 472, 9 N.E. 420, 58 Am. Rep. 53: ‘That, where the voidable act of an infant is disaffirmed, it avoids the contract ab initio, is fully approved. If this is the law, then, when the appellee repudiated his contract, he destroyed it for all purposes. It no longer bound him, nor could he take any benefit from it.’
“See also, Shrock v. Crowl, 83 Ind. 243; 22 Cyc. 616.
“Appellant, as administrator of the estate of the insured, can have no greater right than the insured would have. Having disaffirmed, it can have no right of action on the contract dis-affirmed. If it be said that the partial disaffirmance was without force, then appellant must accept the contract as a whole, and, as the estate was not the beneficiary, it still has no right of action.”

The weight of the authorities seems to be that an infant’s contract is not void but voidable only, upon his election to rescind, or upon the election of his personal representative to rescind, but neither he, nor his personal representative, may rescind a part but not all of the contract. If the contract is rescinded, the contract must foe rescinded as a whole. He cannot claim the benefits and rescind a part.

In this case the petition for interpleader alleges that the administrator of the estate of the minor claims the proceeds of the policies and this is admitted in the answer of the administrator. The administrator in his answer further lays claim to the proceeds of the insurance policies, and on cross examination, at trial, reaffirmed the contract. It therefore affirmatively appears that the administrator has not rescinded the insurance contracts but has affirmed the same and therefore is bound by all the terms thereof.

The administrator further claims, however, that the other claimant, Betty, by fraud and undue influence upon the minor, caused him to name her as beneficiary of the policies, and by threats of criminal prosecution coerced him into so naming her as beneficiary. It is alleged that Betty accused him of being the father of her child —born during her marriage to another man — and threatened to bring criminal prosecution against him unless he married her and made her the beneficiary of the insurance policies.

[19]*19It is clear from the evidence that the deceased minor was unable or unwilling to assimilate an academic education. He could read sufficiently to read the road signs. He had a driver’s license. He was a good automobile mechanic and earned $50 to $60 a week.

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Related

Dryman v. LIBERTY LIFE INS. CO.
57 S.E.2d 163 (Supreme Court of South Carolina, 1950)
Miller v. Gulf Life Insurance Co.
12 So. 2d 127 (Supreme Court of Florida, 1942)
Novosel v. Sun Life Assurance Co. of Canada
55 P.2d 302 (Wyoming Supreme Court, 1936)
Shrock v. Crowl
83 Ind. 243 (Indiana Supreme Court, 1882)
Rice v. Boyer
9 N.E. 420 (Indiana Supreme Court, 1886)
Shroyer v. Pittenger
67 N.E. 475 (Indiana Court of Appeals, 1903)
Wainwright Trust Co. v. Prudential Life Insurance
134 N.E. 913 (Indiana Court of Appeals, 1922)

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Bluebook (online)
14 Fla. Supp. 15, Counsel Stack Legal Research, https://law.counselstack.com/opinion/independent-life-accident-insurance-v-mitchell-flacirct7vol-1958.