Medina v. Safe-Guard Products, International, Inc.

164 Cal. App. 4th 105, 78 Cal. Rptr. 3d 672, 2008 Cal. App. LEXIS 933
CourtCalifornia Court of Appeal
DecidedJune 19, 2008
DocketG038816
StatusPublished
Cited by34 cases

This text of 164 Cal. App. 4th 105 (Medina v. Safe-Guard Products, International, Inc.) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Medina v. Safe-Guard Products, International, Inc., 164 Cal. App. 4th 105, 78 Cal. Rptr. 3d 672, 2008 Cal. App. LEXIS 933 (Cal. Ct. App. 2008).

Opinion

*108 Opinion

SILLS, P. J.

Pedro Medina brought this unfair competition law or UCL (Bus. & Prof. Code, § 17200 et seq.) action based on the fact he had purchased a vehicle service contract, which is allegedly an insurance contract, 1 from a company not licensed to sell insurance in California. (See Ins. Code, § 700 [requiring licenses of insurers].) On a demurrer to the second amended complaint, the trial court reasoned that Medina did not meet the requirement set forth in Business and Professions Code section 17204, as amended by Proposition 64, that a UCL plaintiff have suffered “injury in fact and has lost money or property as a result” of the unfair competition. 2

The irony is that Medina’s class action is predicated on the idea that he bought an absolutely void contract and cannot enforce it (hence he is out the money he paid for the contract, having received nothing for it). 3 That raises the problem of just exactly what are the consequences to a consumer who buys an insurance contract from an unlicensed, out-of-state insurer. Is the consumer really without insurance? We are unaware of any California authority addressing the question, hence we publish our answer to it in this opinion. As readers might readily intuit, California law most certainly does not leave consumers in the lurch when they inadvertently purchase an insurance policy from an unlicensed insurer.

I

Other kinds of contracts might be different, of course, and in appropriate cases an “illegal” contract might not be enforceable at all, by either party. *109 (E.g., Berka v. Woodward (1899) 125 Cal. 119 [57 P. 777] [self-dealing by city council member who sold lumber and materials to city].)

But when it comes to insurance contracts, there can be no doubt that the text of the licensing statute, and the policy behind that statute, require that a consumer who innocently purchased a policy from a company unlicensed in California may still enforce that insurance contract. (Lewis & Queen v. N. M. Ball Sons (1957) 48 Cal.2d 141, 151 [308 P.2d 713] [whether illegal contract is void or voidable depends on “how the aims of policy can best be achieved”].)

A

We begin with the text of the licensing statute itself. Insurance Code section 700 requires every person transacting any class of insurance business in California to have a license from the state Insurance Commissioner. 4 (See also Croskey, et al., Cal. Practice Guide: Insurance Litigation (The Rutter Group 2007) f 1:125, p. 1-30 (rev. # 1, 2007) [“Insurance companies are required to obtain licenses and certificates from the Department of Insurance in order to transact insurance business in California.”].)

*110 Willful violation of the statute can be punished either as a felony or a misdemeanor (commonly called a “wobbler”) 5 as well as by a monetary fine of up to $100,000, or both by fine and imprisonment. (See Ins. Code, § 700, subd. (b) [“. . . a public offense punishable by imprisonment in the state prison, or in a county jail not exceeding one year, or by fine not exceeding one hundred thousand dollars ($100,000), or by both that fine and imprisonment . . . .”].) Also, the violator can be “enjoined by a court of competent jurisdiction on petition of the [Insurance] commissioner.” {Ibid.)

Conspicuously missing, however, from the listed penalties and remedies in the statute is the automatic voiding of any insurance contracts already issued by the unlicensed insurer. As a general rule, as our high court said in City Lincoln-Mercury Co. v. Lindsey (1959) 52 Cal.2d 267, 276 [339 P.2d 851], “The courts will not impose penalties for noncompliance with statutory provisions in addition to those that are provided expressly or by necessary implication.” (Reiterated in People ex rel. Van de Kamp v. American Art Enterprises, Inc. (1983) 33 Cal.3d 328, 334 [188 Cal.Rptr. 740, 656 P.2d 1170] [“However, it is well settled that ‘ “[c]ourts will not impose penalties for noncompliance with statutory provisions in addition to those that are provided expressly or by necessary implication.” ’ ”].) The rule applies with much greater force in cases where the “penalty” of totally voiding the contract would be felt most by an innocent party, such as a consumer who contracted with an out-of-state and unlicensed insurer not knowing that the company possessed no California license.

B

Second, and in that regard, the courts have recognized that there are circumstances when the innocence of a party to an illegal contract must be taken into account in what is called the “in pari delicto” exception. As McIntosh v. Mills (2004) 121 Cal.App.4th 333, 347 [17 Cal.Rptr.3d 66] recently observed: “Because of the harsh results that might be visited on innocent parties to a contract when their agreement is voided for illegality, courts have fashioned exceptions [to a rule of invalidity]. . . . HQ • • • ffi Perhaps the most common exception to the rule of invalidity ... is the in pari delicto exception. At its most fundamental level, the exception allows an illegal contract to be enforced ‘so long as the party seeking its enforcement is less morally blameworthy than the party against whom the contract is being asserted, and there is no overriding public interest to be served by voiding the agreement.’ ” (Italics added.) And obviously an innocent consumer who buys an insurance contract from an unlicensed insurance company is far “less morally blameworthy” than the company that does not disclose its unlicensed status prior to contracting.

*111 C

And then there is common sense, given that the policy of the law requiring insurers to be licensed is obviously to protect consumers, not hurt them. In that regard, we observe that insurance contracts are legally unique: The reason that insurance contracts may be enforced by tort (bad faith) as well as ordinary contract damages is that, unlike all other contracts, a policyholder who is wrongfully denied a claim cannot, by definition, obtain a substitute in the marketplace. Once it is known that the insurable loss has occurred, the insured will not be able to obtain insurance for that loss. (Cates Construction, Inc. v. Talbot Partners (1999) 21 Cal.4th 28, 44 [86 Cal.Rptr.2d 855, 980 P.2d 407

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Bluebook (online)
164 Cal. App. 4th 105, 78 Cal. Rptr. 3d 672, 2008 Cal. App. LEXIS 933, Counsel Stack Legal Research, https://law.counselstack.com/opinion/medina-v-safe-guard-products-international-inc-calctapp-2008.