McQuillan v. Mutual Reserve Fund Life Ass'n

87 N.W. 1069, 112 Wis. 665, 1902 Wisc. LEXIS 3
CourtWisconsin Supreme Court
DecidedJanuary 28, 1902
StatusPublished
Cited by24 cases

This text of 87 N.W. 1069 (McQuillan v. Mutual Reserve Fund Life Ass'n) is published on Counsel Stack Legal Research, covering Wisconsin Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McQuillan v. Mutual Reserve Fund Life Ass'n, 87 N.W. 1069, 112 Wis. 665, 1902 Wisc. LEXIS 3 (Wis. 1902).

Opinions

The following opinion was filed November 29, 1901:

Marshall, J.

As we view this case, several reasons advanced for a reversal, and several reasons given in support of the judgment, need not be considered. The pleadings admit, or the evidence establishes beyond controversy, that payment of the assessment of August 31, 1898, was made by the city of Eau Claire, the owner of the policy, several days too late; that the money was retained by appellant several months with knowledge of all the facts, before its duty to refund the same, or be bound to consider mere time of payment thereof immaterial, was recognized; that no notice whatever that the money was conditionally received and retained was given to the o wner of the policy; and that no valid tender back of the money was made to such owner or to [671]*671any one. The mere retention of the money for a reasonable length of time, for the purpose of ascertaining whether the facts warranted a reinstatement of the forfeited policy under the company’s by-laws, and enabling the assured to comply with the conditions precedent to such reinstatement, did not waive the forfeiture caused by the late payment, if we give effect to the conditional receipt. Rockwell v. Mut. L. Ins. Co. 20 Wis. 335; Miles v. Mut. R. F. L. Asso. 108 Wis. 421; Ronald v. Mut. R. F. L. Asso. 132 N. Y 378; Lewis v. Phœnix M. L. Ins. Co. 44 Conn. 72; Crossman v. Mass. B. Asso. 143 Mass. 435; Unsell v. Hartford L. & A. Ins. Co. 32 Fed. Rep. 443. That rule, however, did not militate against a waiver of the forfeiture occurring by appellant’s retention of the money long after it ascertained the facts as to the ability of McQuillan to secure reinstatement of his membership under its by-laws. In Miles v. Mut. R. F. L. Asso., supra, the rule deduced from the authorities was that acceptance of an overdue assessment on condition that the assured is in. good health does not waive a forfeiture caused by the delinquency if the member is not then in good health and the assurer offers, promptly, to return the money upon discovering that fact. In the absence of any provision of the contract or circumstance to effect a different result, the general rule applies, that the retention of money paid to an insurance company, for an instalment due upon one of its policies, with knowledge of facts rendering the policy void, ratifies and affirms it as a subsisting obligation. Joliffe v. Madison Mut. Ins. Co. 39 Wis. 111; Erdmann v. Mut. Ins. Co. 44 Wis. 376; Underwood v. Iowa Legion of Honor, 66 Iowa, 134; Shea v. Mass. B. Asso. 160 Mass. 289; Gray v. Nat. B. Asso. 111 Ind. 531. In this case appellant retained the money paid upon the policy after a forfeiture had occurred, without notifying the owner that any condition was affixed to such retention, notwithstanding a special request accompanied the money for [672]*672an immediate return of evidence indicating that it had been received and applied for the purposes for which it was sent. Doubtless the rule stated in Shea v. Mass. B. Asso., supra, cited to our attention by respondent’s counsel, that the owner of the policy, where money is paid too late, is entitled to have notice brought home to him of any condition affixed to the retention thereof, is correct and should be applied to this case. Here, appellant, with full knowledge that the policy of insurance had ceased to be binding upon it if it saw fit to insist upon the full effect of the late payment of the assessment, not only retained the money and kept silent, so far as notifying the owner of the policy of its attitude, till the death of the assured, but continued in such attitude till such owner had been put to the trouble and expense of making and transmitting proofs of death, and for a long time thereafter. There can be no question but that, under such circumstances, an insurance company is bound by its conduct indicating a waiver of the forfeiture. The law is so well settled that forfeitures are not favored by courts, and that circumstances similar to those which characterized the conduct of appellant irrevocably indicate an intention on the part of the assurer to treat the insurance contract as subsisting, that no complaint can reasonably be made by appellant because its conduct is held to result that way. When the money for the assessment was received, appellant not only knew the policy of insurance was forfeited, but knew that the money came from the party that, under the terms of the insurance contract, was the owner of the entire beneficial interest therein, and that such party desired the money to be received and retained unconditionally or not at all, and to have evidence of appellant’s position in that regard by due course of the mails. Nevertheless it kept the money without making any attempt to reach the owner of the certificate with information that a condition was affixed to such retention, and its attitude, so far as regards [673]*673such owner, was not changed until the latter had been put to the trouble and expense of making proofs of death, and did not change at all by any legitimate offer to return the money. That such conduct constitutes a waiver of the default in making payment in time, is too clear for discussion.

Appellant, from the beginning to the end of this controversy, seems to have assumed that the city of Eau Claire, the owner of the policy, was bound by the receipt claimed to have been sent to McQuillan. If that were so, it would not avail appellant, as we have seen, because of its failure to return the money seasonably after receiving knowledge of facts rendering compliance with the conditions named in the receipt impossible. While appellant insists that Mc-Quillan and his wife parted absolutely with the policy by the assignment, except his interest in having it extinguish his liability to the city, that situation seems to have been entirely overlooked so far as it bears on appellant’s transactions with him in respect to the receipt. When the assignment of the policy was perfected, the city became substituted, for most purposes, for McQuillan and for his wife as well. All communications thereafter, by the association, affecting the validity of the insurance contract, ivere due to the new party, and it was not affected by any made to Mc-Quillan any more than it would have been by communications made to a mere stranger to the contract. We cannot see any excuse for appellant’s neglect in that regard. It not only knew the city was the sole and unconditional owner of the policy, but that, under the conditions of its ownership, it was expected to keep up the payments thereon, was, to all intents and purposes, except the mere circumstance necessary to the maturity of the contract of insurance, substituted for McQuillan and his wife. Bowen v. Nat. L. Asso. 63 Conn. 460. From this it will be seen that the conditional receipt is immaterial to appellant’s liability. The case stands the same, as regards total forfeiture of the [674]*674insurance contract, as if McQuillan bad not assigned it, and bad made tbe payment in question accompanied by a request for immediate notification as to whether a forfeiture would be insisted upon, and tbe money bad been retained without any condition being brought home to him, as in Shea v. Mass. B. Asso. 160 Mass. 289, which, the court there said, was fatal to the claim of forfeiture.

What has been said does not militate against appellant’s insisting upon the right to recover being limited to the amount due the city of Eau Claire from McQuillan when he died, with interest.

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Bluebook (online)
87 N.W. 1069, 112 Wis. 665, 1902 Wisc. LEXIS 3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcquillan-v-mutual-reserve-fund-life-assn-wis-1902.