McCloskey v. New York Life Insurance

436 A.2d 690, 292 Pa. Super. 1, 1981 Pa. Super. LEXIS 3723
CourtSuperior Court of Pennsylvania
DecidedOctober 30, 1981
Docket592
StatusPublished
Cited by22 cases

This text of 436 A.2d 690 (McCloskey v. New York Life Insurance) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McCloskey v. New York Life Insurance, 436 A.2d 690, 292 Pa. Super. 1, 1981 Pa. Super. LEXIS 3723 (Pa. Ct. App. 1981).

Opinions

HOFFMAN, Judge:

Appellant contends, inter alia, that it is entitled to a judgment n. o. v. because the insurance policy had been fraudulently obtained. We agree and, accordingly, reverse the judgment of the court below and remand for entry of judgment n. o. v. in favor of appellant.1

In early December, 1974, appellee’s husband, Robert J. McCloskey, Jr., applied to appellant for a $25,000 life insurance policy and completed a medical questionnaire designed to reveal any history of various medical conditions including diabetes and heart disease. Mr. McCloskey answered each question in the negative.2 He also submitted to a paramedi[4]*4cal examination which disclosed that he was overweight.3 Appellant subsequently issued a policy with a special rate classification requiring appellee’s husband to pay a premium higher than that of a standard policy. He accepted the policy, and paid the first year’s premium. Mr. McCloskey died within a month after the issuance of the policy, whereupon appellee submitted a claim for the face value of the policy. After an investigation, appellant denied appellee’s claim and, instead, tendered the initial premium with interest. Appellee rejected that offer, commencing this action in assumpsit for the proceeds of the policy.

At trial, appellant defended on the ground that appellee’s husband has fraudulently obtained the policy by misrepresenting his medical condition in the application for insurance. Appellant introduced evidence that Mr. McCloskey did, in fact, suffer from diabetes and that he had suffered a heart attack prior to applying for the policy and that he had undergone a variety of diagnostic tests, a series of x-rays, and a number of electrocardiograms within the period relevant to the application. Although appellee disputed her husband’s knowledge of his medical condition, she contended primarily that appellant had not relied upon her husband’s misrepresentations when it issued the rated policy. The jury returned a $25,000 verdict for appellee. Following the denial of post-trial motions and entry of judgment, appellant [5]*5took this appeal challenging the denial of its motion for judgment n. o. v.

In reviewing an order denying judgment n. o. v., we must view the evidence, together with all reasonable inferences therefrom, in the light most favorable to appellee as the verdict winner. See e. g., Lynch v. Metropolitan Life Insurance Co., 427 Pa. 419, 423, 235 A.2d 406, 409 (1967). See also Atkins v. Urban Redevelopment Authority of Pittsburgh, 489 Pa. 344, 414 A.2d 100 (1980). Judgment n. o. v. should be entered when the facts are such that no two reasonable persons could disagree that the verdict was improper. See e. g., Cummings v. Borough of Nazareth, 427 Pa. 14, 25-26, 233 A.2d 874, 880-81 (1967); Bottorf v. Waltz, 245 Pa.Super. 139, 142-44, 369 A.2d 332, 334 (1976). Accordingly, when the lower court would be warranted in giving binding instructions to the jury, see e. g., Connelly v. Ziegler, 251 Pa.Super. 521, 523-24, 380 A.2d 902, 903 (1977); Albright v. Metropolitan Life Insurance Co., 143 Pa.Super. 158, 164, 17 A.2d 709, 711 (1941), or when the evidence is insufficient to sustain a verdict against the losing party, see e. g., Fitzgerald v. McCutcheon, 270 Pa.Super. 102, 105-06, 410 A.2d 1270, 1271 (1979); Szumski v. Lehman Homes, Inc., 267 Pa.Super. 478, 480-81, 406 A.2d 1142, 1143 (1979); Trawick v. Nationwide Mutual Insurance Co., 242 Pa.Super. 271, 274-75, 363 A.2d 1265, 1266-67 (1965), the court should enter a judgment n. o. v.

Appellant contends that the uncontroverted testimony and documentary evidence established, as a matter of law, that appellee’s husband had fraudulently obtained the life insurance policy by misrepresenting his medical condition in the application for insurance. To avoid its obligations under the life insurance policy, appellant had to prove that: (1) statements of appellee’s husband in his insurance application were false; (2) their subject matter was material to the risk assumed by appellant; and (3) he knew his statements to be false and made them in bad faith. See e. g., Lynch v. Metropolitan Life Insurance Co., supra, 427 Pa. at 424, 235 A.2d at 409; Underwood v. Prudential Insurance [6]*6Co., 241 Pa.Super. 27, 81, 359 A.2d 422, 424-25 (1976). Additionally appellant must establish that it relied upon the misstatements in issuing the policy. Kizirian v. United Benefit Life Insurance Co., 383 Pa. 515, 519, 119 A.2d 47, 49-50 (1956), quoting Evans v. Penn Mutual Life Insurance Co., 322 Pa. 547, 553, 186 A. 133, 138 (1936). The questions propounded in the application for insurance, see note 2, supra, clearly were material to the risk assumed by appellant. See, e. g., Shafer v. John Hancock Mutual Life Insurance Co., 410 Pa. 394,189 A.2d 234 (1963); Kizirian v. United Benefit Life Insurance Co., supra. The uncontroverted testimony and documentary evidence established that Mr. McCloskey answered the questions falsely. Moreover, from that same evidence, we can infer that he knowingly and in bad faith misrepresented his medical condition when answering the medical questionaire.4 See Platt v. John Hancock Mutual Life Insurance Co., 361 Pa. 652, 653-54, 66 A.2d 266 (1949) (when undisputed hospital records established numerous admissions to hospital, diagnosis and treatment for tuberculosis, beneficiary precluded from recovering under life insurance policy; judgment n. o. v. for insurer); Freedman v. Mutual Life Insurance Co. of New York, 342 Pa. 404, 409, 21 A.2d 81, 84 (1941) (“[Wjhere it is established by uncontradicted documentary evidence that the insured has consulted physicians so frequently, or undergone medical or surgical treatment so recently, or of such a serious nature, that a person of ordinary intelligence could not have forgotten these incidents in answering a direct and pointed question in an application for insurance, bad faith may be inferred as a [7]*7matter of law if the insured denies in his answer that any physician has been consulted, or medical or surgical treatment has been received during the period of inquiry.”). See also Shafer v.

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McCloskey v. New York Life Insurance
436 A.2d 690 (Superior Court of Pennsylvania, 1981)

Cite This Page — Counsel Stack

Bluebook (online)
436 A.2d 690, 292 Pa. Super. 1, 1981 Pa. Super. LEXIS 3723, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccloskey-v-new-york-life-insurance-pasuperct-1981.