North American Company for Life and Health Insurance v. Reed

CourtDistrict Court, D. Oregon
DecidedJanuary 27, 2025
Docket3:24-cv-01053
StatusUnknown

This text of North American Company for Life and Health Insurance v. Reed (North American Company for Life and Health Insurance v. Reed) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
North American Company for Life and Health Insurance v. Reed, (D. Or. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

NORTH AMERICAN COMPANY FOR LIFE Case No. 3:24-cv-01053-SB AND HEALTH INSURANCE, FINDINGS AND Plaintiff, RECOMMENDATION

v.

BRANDON D. REED,

Defendant.

BECKERMAN, U.S. Magistrate Judge. Plaintiff North American Company for Life and Health Insurance (“Plaintiff”) filed this diversity action against its insured, Defendant Brandon Reed (“Defendant”), on June 27, 2024. Plaintiff seeks a declaratory judgment rescinding the $500,000 life insurance policy that it issued to Defendant based on false and material misrepresentations that Defendant made in his policy application. After Defendant failed to appear or otherwise defend and the clerk entered Defendant’s default, Plaintiff moved for default judgment under Federal Rule of Civil Procedure (“Rule”) 55(b)(2). The Court has jurisdiction under 28 U.S.C. § 1332(a)(1), but not all parties have consented to the jurisdiction of a magistrate judge under 28 U.S.C. § 636(c). For the reasons explained below, the Court recommends that the district judge grant Plaintiff’s motion for default judgment. BACKGROUND I. FACTS1 Plaintiff is a life insurance company and Iowa corporation with its principal place of business in West Des Moines, Iowa. (Compl. ¶¶ 5, 7, ECF No. 1.) Defendant is an Oregon

citizen who, at all relevant times, resided at 3255 NE Prescott Street in Portland, Oregon. (Id. ¶¶ 6-7.) On July 15, 2022, Defendant applied for a $500,000 life insurance policy on Plaintiff’s online platform. (Id. ¶¶ 6, 9.) In signing his application, Defendant certified that his responses were “complete and true to the best of his knowledge and belief,” and “acknowledged that any person ‘who knowingly present[ed] a false statement in an application for insurance may be guilty of a criminal offense and subject to penalties under state law.’” (Id. ¶ 10.) Defendant also agreed to the application’s “Effective Date” clause, which provided that “no coverage would go into effect” if Defendant was not in the financial condition and state of health that he described.

(Id. ¶ 11.) Relying on Defendant’s certification, responses to its underwriting questions, and assent to the application’s terms, Plaintiff issued a $500,000 life insurance policy to Defendant on the same day that he submitted his application. (Id. ¶¶ 12-13.) In conducting its post-issuance quality control review, Plaintiff obtained Defendant’s medical and court records to verify the truth and

1 Following entry of default, “the factual allegations of the complaint, except those relating to the amount of damages, [are] taken as true.” TeleVideo Sys., Inc. v. Heidenthal, 826 F.2d 915, 917-18 (9th Cir. 1987) (per curiam) (citation omitted); FED. R. CIV. P. 8(b)(6) (stating that the “effect of failing to deny” is that “[a]n allegation—other than one relating to the amount of damages—is admitted if a responsive pleading is required and the allegation is not denied”) (simplified). accuracy of his representations. (Id. ¶¶ 14, 24.) Defendant’s records demonstrated that he was not in the state of health that he described and that despite denying such a criminal history, he had been “convicted, pleaded guilty, or had charges pending in the past ten years for any misdemeanor, felony, or [driving under the influence/driving while intoxicated] charges.” (Id.

¶¶ 14-26, 35-36.) In particular, and relevant to his denial of alcohol-related criminal history, Defendant’s medical records demonstrated that (1) in the previous ten years, medical professionals had diagnosed him with or treated him for chest pain, alcohol abuse (multiple occasions), and one or more of the listed mental health disorders (depression and anxiety), and (2) he consumed more than five alcoholic drinks per week (up to thirty-five weekly drinks). (Id. ¶¶ 15-26, 35-36.) If he disclosed this information, Defendant would have received an “automatic and outright rejection” based on the underwriting standards that Plaintiff programmed into its online policy application platform. (Id. ¶ 27.) Given its discoveries and concerns about additional misrepresentations and omissions

affecting the risks it assumed, Plaintiff sent emails and letters to the addresses that Defendant provided on his application. (Id. ¶¶ 29-30.) In exchange for Defendant’s “consent to the invalidity and rescission of the policy [and] to avoid the costs and expenses of litigation,” Plaintiff’s initial emails and letters (none of which were returned as undeliverable) offered to “restore [Defendant] to his pre-application . . . position by tendering a refund of all premiums paid on the policy, plus interest.” (Id. ¶ 30.) Defendant did not respond. (Id. ¶ 31.) II. PROCEDURAL HISTORY On June 27, 2024, less than two years after issuing Defendant’s policy, Plaintiff filed this case in the U.S. District Court for the District of Oregon. (Id. at 13.) Plaintiff invokes the Court’s diversity jurisdiction under 28 U.S.C. § 1332(a)(1), and seeks a declaration under the Declaratory Judgment Act, 28 U.S.C. § 2201(a), rescinding the policy. (Id. ¶¶ 7, 34.) In the alternative, Plaintiff seeks a declaration that the policy was “void ab initio—null from the beginning,” WB Music Corp. v. Royce Int’l Broad. Corp., 47 F.4th 944, 950 (9th Cir. 2022), because Defendant was not in the state of health that he described in his application and thus he

failed to satisfy an “express condition precedent necessary to form a valid contract.” (Compl. ¶ 44; ECF No. 14 at 2.) On July 24, 2024, about one month into this litigation, the Court granted Plaintiff’s motion to effect service by publication and for an extension of time in which to do so. (ECF Nos. 7, 8.) Plaintiff filed proof of service and moved for entry of default on September 26, 2024. (ECF Nos. 10-11.) Given Defendant’s failure to appear or otherwise defend, the clerk entered Defendant’s default (ECF No. 12) in accordance with Rule 55(a). See FED. R. CIV. P. 55(a) (stating that “[w]hen a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend, and that failure is shown by affidavit or otherwise, the clerk must enter the

party’s default”). Plaintiff subsequently moved under Rule 55(b)(2) for default judgment. (ECF No. 13.) LEGAL STANDARDS “In reviewing a [motion for] default judgment, [a] court takes ‘the well-pleaded factual allegations’ in the complaint ‘as true.’” DIRECTV, Inc. v. Hoa Huynh, 503 F.3d 847, 854 (9th Cir. 2007) (quoting Cripps v. Life Ins. Co. of N. Am., 980 F.2d 1261, 1267 (9th Cir. 1992)). A court, however, does not accept as true factual allegations “relating to the amount of damages.” Geddes v. United Fin. Grp., 559 F.2d 557, 560 (9th Cir. 1977) (citing Pope v. United States, 323 U.S. 1, 12 (1944)). Nor does a court accept as “admit[ted] facts that are not well-pleaded or [amount to] conclusions of law.” DIRECTV, 503 F.3d at 854 (simplified).

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North American Company for Life and Health Insurance v. Reed, Counsel Stack Legal Research, https://law.counselstack.com/opinion/north-american-company-for-life-and-health-insurance-v-reed-ord-2025.