Peter Paluch v. Cuna Mutual Group

CourtNew Jersey Superior Court Appellate Division
DecidedOctober 24, 2024
DocketA-1804-22
StatusUnpublished

This text of Peter Paluch v. Cuna Mutual Group (Peter Paluch v. Cuna Mutual Group) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peter Paluch v. Cuna Mutual Group, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-1804-22

PETER PALUCH,

Plaintiff-Appellant,

v.

CUNA MUTUAL GROUP, CMFG LIFE INSURANCE COMPANY, and NOVA CREDIT UNION,

Defendants-Respondents. __________________________

Submitted October 1, 2024 – Decided October 24, 2024

Before Judges Smith and Vanek.

On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Docket No. L-5441-20.

Schenck, Price, Smith & King LLP, attorneys for appellant (Eric A. Inglis, on the briefs).

Faegre Drinker Biddle & Reath LLP, attorneys for respondents (Kate L. Villanueva and Jamie M. Campisi, on the brief).

PER CURIAM Plaintiff Peter Paluch appeals from a January 6, 2023 Law Division

order granting summary judgment to defendants—CMFG Life Insurance

Company (CMFG), CUNA Mutual Group (CUNA), and Nova Credit Union

(Nova)—and dismissing his complaint with prejudice. Based on our thorough

review of the record and prevailing law, we affirm in part and reverse and

remand in part.

I.

In reviewing the trial court's order granting summary judgment to

defendants, we glean the following salient facts from the motion record,

viewed in the light most favorable to plaintiff as the non-moving party. On

March 9, 2010, plaintiff and his wife, Lesia, 1 each submitted applications

through CUNA to obtain a CMFG long-term care insurance policy (the

policy). Both plaintiff and Lesia chose to pay their policy premiums quarterly

through automatic withdrawals from the couple's jointly held Nova bank

account on the twenty-sixth day of the payment month. Doing so afforded

plaintiff and Lesia six percent discounts on their premium payments.

Plaintiff's discounted quarterly policy premium payment was $1,236.46, and

Lesia's was $1,055.14.

1 Because plaintiff and his wife share a surname, we refer to Lesia by her first name, and intend no disrespect in doing so. A-1804-22 2 The policy contained a provision explaining coverage remained in effect

"as long as [the insured] pay[s] [their] premium on time." In the event of non-

payment, coverage under the policy would terminate at 12:01 a.m. on the

sixty-sixth day after the default date.

The policy contained procedures for reinstatement in the event of

termination due to non-payment. Section 7.8 titled "REINSTATEMENT DUE

TO UNINTENTIONAL LAPSE," states that coverage would be reinstated if

the policyholder provided "adequate proof" they were chronically ill at the

time of the lapse. Absent such proof, a policyholder could request

discretionary reinstatement within five months of the policy termination, to be

considered by CMFG upon payment of any past-due premiums.

One of plaintiff's quarterly premium payments was due on October 1,

2017. The transaction could not be completed because there were insufficient

funds in plaintiff's account.

In an October 30, 2017 letter, CMFG notified plaintiff his "premium

payment in the amount of $1,236.46 [was] returned due to insufficient funds."

CMFG placed the policy on "direct quarterly billing," which removed the six

percent discount. The letter further advised plaintiff would be receiving an

A-1804-22 3 invoice in the mail for the full quarterly premium amount of $1,420.61. 2

Plaintiff was also directed to call CMFG as soon as possible if he wished to

opt back into automatic withdrawal with the accompanying discount.

On October 31, Lesia called CMFG. The parties disagree as to what was

discussed during the call. Plaintiff maintains that Lesia called CMFG on

behalf of both herself and plaintiff to ask CMFG to reprocess the quarterly

premium withdrawals for each of their policies since they had placed sufficient

funds in their bank account. Plaintiff alleges he "was close by during the call

and heard [Lesia's] side of the conversation and an occasional audible response

from the person on the other end of the line." Plaintiff states he heard Lesia

receive "personal assurance" that both policies would remain in "full force and

effect."

Contemporaneous notes documented within CMFG's customer

management system indicate Lesia only asked to have her own policy placed

back on automatic withdrawal since she had sufficient funds in her account to

2 Defendants contend there was no increase in plaintiff's policy premium but, rather, the $1,420.61 bill reflected the $1,236.46 quarterly payment , without the six percent automatic withdrawal discount. However, if the six percent discount was removed from the full quarterly payment, the new payment amount would be $1,335.38. Neither the parties nor the trial court addresses the mathematical calculation.

A-1804-22 4 cover the cost. CMFG's notes do not evidence plaintiff's account was

discussed during that call, and plaintiff's customer management profile does

not have a corresponding entry related to his account.

On November 5, CMFG mailed plaintiff an invoice for $1,420.61, the

full amount of the premium payment due on October 1. The invoice included a

"lapse notice" which alerted plaintiff his coverage would be "terminated due to

non-payment of [the] required premium" if full payment was not made by the

expiration of the sixty-five-day grace period. Plaintiff and Lesia certified they

called CMFG again in the weeks after the October 31 phone call and were told

the policy issues were rectified.

After the sixty-five-day grace period expired, CMFG terminated

plaintiff's coverage. Plaintiff was not aware his policy was terminated until

the next premium payment was due for Lesia's policy.

On February 6, 2018, plaintiff called CMFG and asked that his policy be

reinstated. A few days later, CMFG sent plaintiff a letter advising his policy

could be considered for reinstatement if he completed an application, provided

medical records for the past three years, and paid the outstanding balance due

on his account, which at that point totaled $2,841.22.

A-1804-22 5 On February 19, plaintiff responded in writing and expressed "concerns

as to [CMFG's] operational procedures and breach of [their] agreement."

Plaintiff alleged in the letter that Lesia called to reinstate his policy and

attached a completed reinstatement form, but did not include his medical

records because "[t]here ha[d] been no change in [his] medical condition ."

Plaintiff requested again that both his policy and Lesia's "should be set up for

direct withdrawals from [his] . . . account at $1,055.14 for [Lesia] and

$1,236.46 for [plaintiff], to be deducted on the last business day of the billing

quarter."

On April 24, 2018, CMFG sent plaintiff another letter reiterating he

could be considered for reinstatement if he completed an application, provided

his medical records for the past three years, and paid the outstanding balance

due on his account, which then totaled $4,261.83. On May 10, plaintiff replied

to that letter by completing the application CMFG sent him, noting on the

document that he had "periodic medical exams" and enclosing a "visit

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Peter Paluch v. Cuna Mutual Group, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peter-paluch-v-cuna-mutual-group-njsuperctappdiv-2024.