Julien v. Federal Mutual Fire Insurance

4 Balt. C. Rep. 197
CourtBaltimore City Court
DecidedMarch 15, 1923
StatusPublished

This text of 4 Balt. C. Rep. 197 (Julien v. Federal Mutual Fire Insurance) is published on Counsel Stack Legal Research, covering Baltimore City Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Julien v. Federal Mutual Fire Insurance, 4 Balt. C. Rep. 197 (Md. Super. Ct. 1923).

Opinion

FRANK, J.

These two eases, by agreement of the parties, were tried together before the Court without a jury, upon agreed statement of facts. They are actions upon two fire insurance policies, each for $2,000, issued by the defendants in the two cases respectively. No question arises as to the execution and delivery of the policies, the payment of the premiums, the facts of loss and of coverage, and that the plaintiff is entitled to recover, if at all, the full face amount of both policies.

Two defenses are interposed:

First: That the plaintiff failed to file formal proofs of loss within sixty days after the date of said loss, as required by both policies.

Second: That the warranty in what is known as the “clear space clause” of both policies was broken and that, as a consequence, the policies by the [198]*198express terms of the warranty became null and void. The language of these “clear space clauses” is fully quoted in paragraph 14 of the agreement and will not be set out here at length.

First: I find sufficient evidence of waiver of the requirement that formal proofs of loss be filed to require the submission of the question of waiver to the Court sitting as jury.

By the agreement above referred to it appears: That the plaintiff promptly notified the defendants that he had suffered a total loss; that defendants sent their adjuster to investigate and report on the said loss and that the adjuster reported to the defendants that there was a violation of the “clear space clause”; that demand was made, immediately after the fire, for the full face amount of each of the policies of insurance; that about eight days before the institution of these actions, plaintiff’s counsel visited the offices of the said defendants and made demand for the payment of the said policies, but that said demand was refused by officers of said defendants for the reason that the policies were vitiated under the “clear space clause” of the policies; that no reference was made at that time to the absence, or lack of filing, of proofs of loss, nor had any such reference been made to the plaintiff, his counsel or agents, until some considerable period of time after these suits had been brought.

The defendant’s third prayer asks the Court to rule as matter of law that under the uncontradicted evidence in this case, the plaintiff did not furnish proofs of loss as required by the policies and that there is no evidence legally sufficient to show any waiver by the defendants of this requirement.

It is true that no formal proofs of loss were ever furnished as required by the policies, and unless the conduct of the defendants above described amounted to legally sufficient evidence of a waiver this prayer should be granted. About eight days before the commencement of these actions, the defendants absolutely denied all liability, but solely on the ground that the warranty of the “clear space clause” had been broken, and neither then nor at any time before was any reference made to the failure to file proofs of loss. This being agreed to in the case, the Court must decide as a matter of law as to whether such conduct, together with the other acts above recited amounted to evidence of a waiver. In many jurisdictions, it is held that there can be no waiver unless the circumstances create an estoppel on the X>art of the insurer to set ux> that no X>roofs of loss have been filed. Where this rule prevails, the assured must show that he has been prejudiced by the conduct of the insurer, i. e., that but for such conduct he would have filed proofs in ample time. This rule necessarily involves the requirement that the conduct relied on as constituting the waiver must have occurred before the expiration of the stixmlated period of time for the filing of xiroofs.

In Maryland (also in New York and Indiana and probably also in Missouri), estoppel is not a necessary element of waiver. The acts showing the intention of the insurer to waive may, therefore, occur after the period limited for the filing of proofs, since no prejudice to the insured need be shown. 4 Cooley’s Briefs on Insurance, 3481, 3483, 3539.

A denial of liability by the insurer on other grounds than failure to file X>roofs of loss is generally held to amount to such a waiver. 4 Cooley, 4531; Germania Fire Ins. Co. vs. Pitcher, 160 Ind. 392.

And such a denial will be sufficient where no reason therefore is given. Allegre vs. Md. Ins. Co., 6 H. & J. 408.

Some of the authorities hold that such denial will be effective even though made for the first time in the pleadings or even at the trial of the case. 4 Cooley, 3541.

As stated above, in Maryland estoppel is not a necessary element of waiver. Therefore, the fact that the denial of liability took place subseqent to the expiration of the sixty days’ period does not preclude the possibility of a waiver. Under the agreed facts in this case, evidence of such a waiver is afforded. Caledonan Ins. Co. vs. Traub, 80 Md. 214, 223, citing Fireman’s Ins. Co. vs. Floss, 67 Md. 417.

In determining whether there has been a waiver, the facts must be submitted to the jury, but the Court instructs the jury as to the legal effect of their finding such facts. Sumwalt [199]*199Co. vs. Knickerbocker Co., 112 Md. 437, 444, and cases cited.

The defendant’s third prayer is, therefore, refused.

Second: The defendants further contend that the warranty in the “clear space clause” of the policies was broken and that the policies were thereby rendered null and void. This clause in effect requires that a continuous clear space of 300 feet be maintained between the property insured and any wood-working or manufacturing establishment or dry kiln. Such a clause is a valid continuing warranty and a breach thereof avoids the policy. Rife vs. Lumber Underwriters (CCA 6th Circ. 1913), 204 Fed. Rep. 32, 36; Liverpool & L. & G. Ins. Co. vs. Richardson Lbr. Co. (Okla. 1922), 69 Pac. Rep. 938; The Michigan Shingle Co. vs. The London and Lancashire Fire Ins. Co., 91 Mich. 441 (1892) ; Gough vs. Jewett (1898), 52 N. Y. Supp. 707; Hartford Fire Ins. Co. vs. Post (Tex. 1901), 62 S. W. Rep. 140.

By the agreed facts in this case, it appears that the lumber insured and destroyed at its nearest point was about 550 feet away from a saw mill. After the policies in suit were issued, but before the fire, a building was erected, at no point nearer to the saw mill than 400 feet. The dimensions of this building were 50 feet by 50 feet and its nearest side was 100 feet from said lumber. At the time of the fire (June 26th, 1920), this building, although roofed, had never been used. It was intended to be used as a planing mill for the preparation or milling of lumber. There remained a lot to do before the building could be so operated, as it was necessary to assemble the machinery and put it in working order. There was no power in this building. In fact, it was not operated at all until April, 1921, and then oidy in a small way and was finally put in regular use in August, 1921.

The saw mill clearly had a continuous clear space of more than 300 feet (400 feet in fact) between it and the property insured and there was, therefore, no breach of warranty unless the building, uncompleted at the time of the fire, was itself “a wood-working or manufacturing establishment or dry kiln,” within the meaning of the covenant. Its destined use was certainly embraced within the language of the covenant.

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Related

Sumwalt Ice & Coal Co. v. Knickerbocker Ice Co.
77 A. 56 (Court of Appeals of Maryland, 1910)
Smith v. National Fire Insurance Co. of Hartford
95 S.E. 562 (Supreme Court of North Carolina, 1918)
Liverpool, London & Globe Insurance v. T. M. Richardson Lumber Co.
1902 OK 39 (Supreme Court of Oklahoma, 1902)
Hartford Fire Insurance v. Post
62 S.W. 140 (Court of Appeals of Texas, 1901)
Gough v. Jewett
32 A.D. 79 (Appellate Division of the Supreme Court of New York, 1898)
Allegre v. Maryland Insurance
6 H. & J. 408 (Court of Appeals of Maryland, 1824)
Spring Garden Mutual Insurance v. Evans ex rel. Riley
9 Md. 1 (Court of Appeals of Maryland, 1856)
Germania Fire Insurance v. Pitcher
64 N.E. 921 (Indiana Supreme Court, 1902)
President & Directors of the Firemen's Insurance v. Floss
10 A. 139 (Court of Appeals of Maryland, 1887)
Caledonian Insurance v. Traub
30 A. 904 (Court of Appeals of Maryland, 1894)
Michigan Shingle Co. v. London & Lancashire Fire Insurance
51 N.W. 1111 (Michigan Supreme Court, 1892)

Cite This Page — Counsel Stack

Bluebook (online)
4 Balt. C. Rep. 197, Counsel Stack Legal Research, https://law.counselstack.com/opinion/julien-v-federal-mutual-fire-insurance-mdcityctbalt-1923.