Pennsylvania National Mutual Casualty Insurance v. Powers Trucking Co.

2 Pa. D. & C.4th 57, 1989 Pa. Dist. & Cnty. Dec. LEXIS 293
CourtPennsylvania Court of Common Pleas, Clinton County
DecidedFebruary 10, 1989
Docketno. 21-88
StatusPublished
Cited by1 cases

This text of 2 Pa. D. & C.4th 57 (Pennsylvania National Mutual Casualty Insurance v. Powers Trucking Co.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Clinton County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pennsylvania National Mutual Casualty Insurance v. Powers Trucking Co., 2 Pa. D. & C.4th 57, 1989 Pa. Dist. & Cnty. Dec. LEXIS 293 (Pa. Super. Ct. 1989).

Opinion

BROWN, P.J.,

This is a declaratory-judgment action brought by plaintiff seeking a judicial affirmation of its attempted cancellation of a workmen’s compensation insurance policy issued to defendant Powers. Defendant Powers has filed a motion for summary judgment on the basis that there are no disputed material facts which bear on the issue of whether plaintiff was permitted by law to retroactively cancel the policy or, in the alternative, whether plaintiffs cancellation if permitted by law was done in accordance with law.

The underlying facts unfold with the observation that plaintiff had issued a workmen’s compensation policy to defendant Powers for the period of January 15, 1987 through January 15, 1988. Powers was apparently unable to pay the premiums which were due on that policy and they were financed through Penco Finance Company. Penco is a wholly-owned subsidiary of plaintiff. Penco thus paid the full insurance premium to Penn National at the begin[59]*59ning of the policy period and Powers then was under an obligation to make periodic payments to Penco to cover the amount financed in premiums.

During the term of the policy Powers experienced difficulties in meeting the payments due to Penco for the financed insurance premiums. Three cancellation notices were sent to Powers. Powers made payments to Penco on August 7, 1987 and on September 24, 1987.

On July 21, 1987 plaintiff sent a notice to Powers reciting that the policy was being cancelled for nonpayment of premiums effective August 11, 1987.

On October 13, 1987 defendant Powers went to his insurance agent, defendant Davis, inquiring about the status of his workmen’s compensation policy. Davis then contacted plaintiff on Powers’ behalf and after some negotiations it was agreed that the policy would be retroactively reinstated if Powers met certain conditions, one of which included his asserting he did not know of the existence of any workers’ compensation losses or claims. In accordance with this understanding Powers signed a statement which read:

“We at Powers Trucking Company knows (sic) of no outstanding claims on our workmen’s compensation from September 11, 1987, to present.” Plaintiff then reinstated the policy retroactive to August 11, 1987.

On the evening of October 12, 1987, defendant Vames, who was an employee of Powers, was injured while driving a truck in Ohio. At the time of the negotiations with plaintiff regarding reinstatement of the policy, Powers was aware that Vames had been in the accident on the previous evening. Plaintiff claimed that the notice which was provided to it by Powers was fraudulent and on November 13, 1987 notified Powers that the reinstatement of the [60]*60policy was rescinded retroactively to August 11, 1987 on the basis that Powers had lied when he denied knowledge of any workers’ compensation claims. On December 8, 1987 defendant Vames filed a petition for workmen’s compensation seeking benefits from plaintiff as Powers’ carrier.

Powers’ first argument is predicated upon what it perceives as a statutory prohibition against cancel-ling workmen’s compensation policies on a retroactive basis except for non-payment of premium.

Powers in support of its position initially cites 40 P.S. §811 which provides in pertinent part:

“[S]uch obligation shall not be affected by any default of the insured, after an accident or after disability caused by occupational disease, in the payment of premiums or in the giving of any notices required by such policy or otherwise.”

Powers has further argued under the provisions of 40 P.S. §813 that a workmen’s compensation policy may not be cancelled or terminated by an insurer during the term of the policy except for non-payment of the premium. On this subject section 813 provides in pertinent part as follows:

“Except for non-payment of premiums, no policy of insurance issued or renewed against liability under the. . . ‘Pennsylvania Workmen’s Compensation Act’... or insuring an employer against liability for all sums such employer shall become legally obligated to pay any employee of his as damages because of bodily injury by accident or disease, including death at any time resulting therefrom, sustained by such employee arising out of and in the course of his employment, may be cancelled or terminated by an insurer during the term of the policy.”

Aside from disagreeing with Powers’ interpretation of the law prohibiting the rescission of the workmen’s compensation policy, defendant has also [61]*61argued that there is a genuine issue about a material fact which is relevant to the issue. As the court understands plaintiffs brief it is alleged that there was “confusion as to whether the Powers’ policy was in force.” The court has some difficulty accepting this proposition since it would appear from the pleadings that the policy after having been purportedly cancelled on July 21, 1987 (effective August 11, 1987) by plaintiff was then reinstated as previously discussed on October 13, 1987 effective back to August 11, 1987.

Another aspect of plaintiff’s position seems to be that there is a disputed fact over the degree of fraud perpetrated by Powers in securing a reinstatement of the policy. Again the court disagrees with this position since Powers has conceded the fraud alleged by plaintiff in its complaint. Therefore the court does not believe that the degree of fraud perpetrated by Powers is an issue at the present time since the court has to assume that Powers did fraudulently induce plaintiff to reinstate the policy.

In the court’s judgment the facts that are necessary in dealing with this issue must first be identified and then a secondary inquiry must take place as to whether any of those facts are in dispute so as to preclude any attempt to resolve the matter by way of a summary judgment. The court concludes that it is not in dispute that on October 13, 1987, Powers and Davis together persuaded plaintiff to reinstate the policy retroactive to Aúgust 11, 1987. This would establish then for present purposes the necessary fact that a workmen’s compensation policy was in existence at the time of the October 12, 1987 accident.

The second , fact that does not seem to be in dispute is that on November . 13, 1987, plaintiff [62]*62notified Powers that the reinstatement of the policy was being rescinded because of Powers’ fraudulent misrepresentations.

Thus the setting that a policy of insurance existed on October 12, 1987 is present. Also present is the setting that plaintiff on November 13, 1987, attempted to rescind the reinstatement of that policy. The question that then can be addressed from those two givens is whether the provisions of law as cited by Powers prohibited such an action by plaintiff.

Both parties have cited various cases in support of their position with all of these cases having one thing in common, and that is that none of them have dealt directly with the purported cancellation of a workmen’s compensation policy. Preliminarily the court would note that its sense of the legislative intent from the statutes in question is that the legislature wanted to protect workers who are covered by workmen’s compensation policies by prohibiting such cancellations. As such the workers can be best perceived as being in a position analogous to that of a third-party beneficiary to a contract.

Plaintiffs position on this issue as stated on page 2 of its brief is that the law of Pennsylvania does not

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Bluebook (online)
2 Pa. D. & C.4th 57, 1989 Pa. Dist. & Cnty. Dec. LEXIS 293, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pennsylvania-national-mutual-casualty-insurance-v-powers-trucking-co-pactcomplclinto-1989.