Peoples' Mutual Fire Ins. v. Bowersox

3 Ohio Cir. Dec. 218
CourtWilliams Circuit Court
DecidedJune 15, 1891
StatusPublished

This text of 3 Ohio Cir. Dec. 218 (Peoples' Mutual Fire Ins. v. Bowersox) is published on Counsel Stack Legal Research, covering Williams Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peoples' Mutual Fire Ins. v. Bowersox, 3 Ohio Cir. Dec. 218 (Ohio Super. Ct. 1891).

Opinion

SCRIBNER, J.

The policy sued upon in the court below was issued July 22, 1886. The loss-occurred August 3, 1889.

The by-laws of the company, which formed a part of the policy, contained the following provision:

“This company will not be liable under and by virtue of any policy • issued by it * * * if the assured shall procure or suffer to accrue any incumbrance covering the property therein specified or any part thereof. *' * * In each and every such case the insurance thereunder is void, and immediately ceases and determines.”

After the issuing of the policy in question, the assured executed and delivered to Farnam & Co. its two promissory notes with cognovits attached, in the usual form. One of these notes was for $700, dated March 1, 1887, and payable ninety days after date. The other was for $846.67, dated January 10, 1888, payable six months after date.

Judgment was rendered upon these notes, in the court of common pleas of Williams county, by virtue of the cognovits forming a part thereof, July 9, 1889. And these judgments, thereupon became liens upon a portion at least, of the property covered by the policy of insurance.

Upon the trial in the court below, the jury were instructed that the judgments so obtained were not “incumbrances” within the meaning of the language of the by-laws above quoted. Exception was taken to this ruling, and the only -question now presented is-as to the correctness of the instruction so given.

1. The view taken by the court of common pleas is directly supported by the decisions of the Court of Appeals of New York in the following cases: Bailey v. Fire Ins. Co., 80 N. Y., 211 ; Green v. Fire Ins. Co., 82 N. Y., 517. To the same effect is the case of Chamberlin v. Ins. Co., 3 N. Y. Supplement, 701. The supreme court of Indiana has made a like ruling. Phoenix Ins. Co. v. Pickel, 119 Ind., 135.

Cases holding or appearing to hold a different doctrine are cited by counsel for plaintiff in error. The following are the leading authorities relied upon: Egan v. Ins. Co., 5 Denio, 326. In that case the application contained a stipulation “that if the assured should suffer a judgment which should be a lien upon the insured premises without communicating it to the insurers,” the policy should be void. It was held that a violation of this stipulation avoided the policy. This ruling was approved in Bailey v. Fire Ins. Co., supra, the court there holding, however, that the term "incumbrance” contained in a policy 'of insurance, "does not apply to incumbrances by judgment or otherwise in invitum, by operation of law.” Of course, where by the express terms of the contract, the attaching of a judgment lien is to annul the policy, the court must, in the absence of statutory regulation to the contrary, give effect to the stipulation.

In Brown v. Ins. Co., 41 Pa. St., 187, the policy contained this condition:

“Should there, during the hie of the policy, an incumbrance fall or be exhibited atpon the property insured, sufficient to reduce the real interest of the insured in the same to a sum only equal to or below the amount insured, and the assured shall'neglect or fail to obtain consent of the company thereto, then and in that case the policy shall be void.”

The trial court, among other things, found:

“The records of the court show that after (the date of the policy) and before the fire, judgments to a considerable amount were recovered against both the plaintiffs, and to a very large amount additional against one of them. It is not pretended that any ■notice of either was given to the company.”

The supreme court held, that upon notice of the liens, “the company would bave the right to rescind the policy on repayment of a proportionate part of the premium;” and that, upon the facts as above found, the parties insured were not entitled to recover.

[220]*220In Insurance Co. v. Berger, 42 Pa. St., 285, the following proposition was. determined:

“A clause in a policy of insurance that it should cease at and from the time the property hereby insured shall be levied on or taken into possession or custody, under any proceeding at law or equity, is to be construed as meaning an actual levy and change of possession under it; a mere notice of levy by the officer charged therewith to the defendants, at their store, without his taking the good' insured into possession of custody, though good as a levy; will not defeat the policy.”

In Insurance Co. v. Gottsman, 48 Pa. St., 151, it was held that

“The stipulation in an insurance policy requiring the person whose property is insured to give notice to the insurance company of an incumbrance or levy made upon the property insured, is a substantive and material part of the contract;” also, that “where two executions were levied before the policy took effect, and one afterwards, all of which liens lasted until the fire occurred by which plaintiff’s property was burned — held, that notice ought to have been given to the insurance company, and that for the want of such notice the right to recover was forfeited.”

The statement of the case (p. 152) also shows that the stipulation as to incumbrances, by express language, included judgments and liens of every description.

So in Seybert v. Ins. Co., 103 Pa. St., 282, the policy provided that

‘'‘If, after insurance, the risk shall be increased by any means whatever, or if the property * * * shall be incumbered by judgment, mortgage or otherwise * * * and the assured shall neglect or fail to give written notice thereof, and pay, etc., such insurance shall be void, and of no effect.”

It was very properly held that a judgment was an incumbrance within the meaning of the policy.

In Bowman v. Ins. Co., 40 Md., 620, the policy sued upon contained the following proviso:

“Any incumbrance on the property hereby insured, whether existing at the time of issuing this policy or imposed subsequently thereto, must be assented to by the company, otherwise the policy shall be void.”

The existence of certain judgments which were liens upon the property, was not 'made known to the company. The court held as follows: “The judgment lien constituted an incumbrance within the meaning of the policy; and, as the plaintiff failed to make known its existence at the time of effecting the insurance, the policy was void.” “As to what would be the effect on the policy of a judgment rendered against the insured in invitum, quaere',” upon this last proposition the judge who delivered the opinion, added:

“As to judgments in existence at the date of the policy, and such as are thereafter rendered against the insured, by his consent or confession, and which constitute liens on the property insured, we think they are clearly within the meaning of the condition.”

Some other cases bearing upon this proposition have been cited, but they are of the same general character. The Pennsylvania cases, it will be noted, do not directly meet the point. The incumbrances there in question, were either expressly, or by fair construction, within the terms of the policy. In the Maryland case, the judge delivering the opinion was in doubt as to whether or not a judgment recovered in invitum, is such an incumbrance as would invalidate the policy.

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Related

Green v. . Homestead Fire Insurance Co.
82 N.Y. 517 (New York Court of Appeals, 1880)
Cook v. . Freudenthal
80 N.Y. 202 (New York Court of Appeals, 1880)
Egan v. Mutual Insurance
5 Denio 326 (New York Supreme Court, 1848)
Chamberlain v. Insurance Co. of North America
3 N.Y.S. 701 (New York Supreme Court, 1889)
Moon v. Jennings
20 N.E. 748 (Indiana Supreme Court, 1889)
Bowman v. Franklin Fire Insurance
40 Md. 620 (Court of Appeals of Maryland, 1874)

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Bluebook (online)
3 Ohio Cir. Dec. 218, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peoples-mutual-fire-ins-v-bowersox-ohcirctwilliams-1891.