Phalen Park State Bank v. Reeves

251 N.W.2d 135, 312 Minn. 194, 1977 Minn. LEXIS 1628
CourtSupreme Court of Minnesota
DecidedFebruary 18, 1977
Docket45882
StatusPublished
Cited by21 cases

This text of 251 N.W.2d 135 (Phalen Park State Bank v. Reeves) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Phalen Park State Bank v. Reeves, 251 N.W.2d 135, 312 Minn. 194, 1977 Minn. LEXIS 1628 (Mich. 1977).

Opinions

Yetka, Justice.

This is an action brought by the Phalen Park State Bank (the bank) against FCM Insurance Company (FCM) to recover under the mortgage clause contained in a fire insurance policy issued by FCM to the bank’s mortgagors, Jean J. and William Reeves (the insureds). The insureds intervened in the action as [196]*196plaintiffs asserting their claim to the insurance proceeds. The case was tried before a jury February 18, 1975. At the conclusion of the trial, the court granted the bank’s motion for directed verdict against FCM, and ordered judgment entered for the bank, ruling that it was entitled to recover $38,686.38, the full amount due on the mortgage note. As to the insureds’ claim, the jury returned a special verdict finding that the fire which destroyed the insured property had been deliberately set at the instance and request of William Reeves. Both FCM and the insureds appealed from the judgment and the trial court’s order denying their motions for new trial. However, the insureds’ appeal has been dismissed by order of this court. As to FCM’s appeal, we reverse and remand for a new trial.

On August 3, 1971, the insureds executed a mortgage note in favor of the bank in the amount of $34,000 bearing interest at the rate of 7 1/2 percent per annum. The note was secured by a mortgage of the insured premises. Of the proceeds of the loan, $22,715.06 was disbursed by the bank according to the insureds’ instructions and the balance of $11,284.94 was retained in escrow to secure the bank against an outstanding real estate tax lien and an attorneys lien.

The insureds defaulted on the note and consequently the bank commenced foreclosure proceedings pursuant to Minn. St. c. 580. The bank purchased the property at the sheriff’s sale on December 27, 1972, for $38,162.17, the balance then due on the mortgage note plus foreclosure costs.

In December 1972 the bank received notice that the fire insurance provided by the insureds had been terminated. It notified the insureds of the termination and demanded that they replace the insurance. In February 1973 the insureds contacted insurance agent Robert Averbeck, who secured a replacement policy through FCM in the amount of $50,000. The policy was issued by FCM on February 11, 1973, and delivered to the Reeves on March 8,1973. On March 15, 1973, the building on the subject property was destroyed by fire.

[197]*197The bank filed its proof of claim July 2, 1973, 5 days after the insureds’ period of redemption from the foreclosure sale had expired. The bank presently holds the fee interest in the insured property.

On appeal FCM contends that the policy was invalidated by the bank’s failure to disclose the foreclosure of its mortgage at the time the policy was issued and by the absence of any insurable interest in the bank. Alternatively, FCM argues that if the policy is valid then the bank’s recovery must be reduced by the amount of the escrow funds retained by it, and that upon payment of that reduced amount the bank should be directed, in accordance with the provisions of the mortgage clause, to convey its fee interest in the insured property to FCM.

Averbeck, the agent who arranged the insurance policy, testified that he called the bank to advise it that a replacement policy was being issued by FCM and that coverage had been bound. He did not request any information from the bank. He further testified that he had made no inquiry of the insureds regarding the status of the mortgage, that he had written thousands of policies without ever requesting such information, and that he had never seen an insurance application form which requested such information. The insurance application submitted by the insureds required no such information. Averbeck did testify that if he had known of the foreclosure, he would not have placed the insurance.

Similarly, FCM’s vice president stated it was the company’s policy to decline to insure property under foreclosure. A property underwriting supervisor for Aetna Insurance Company testified that insurers 'normally refuse to insure such property; however, he also stated that his company had no systematic way of detecting the existence of a mortgage foreclosure.

We are unaware of any authority, nor has any been cited, requiring a mortgagee, upon application by its mortgagor for a policy of fire insurance covering the mortgaged premises, to disclose to the insurer the foreclosure of the mortgage. While the [198]*198bank’s interest is protected under the policy’s mortgage clause, it is not the insured and is not required to join in the application, nor does the policy itself impose any duty of disclosure upon it. Moreover, the record fails to reveal an intentional withholding of notice of the foreclosure or other breach of good faith or fair dealing on the part of the bank. The failure of FCM to discover the foreclosure must rest entirely on its shoulders for not making adequate inquiry.

While the policy withstands attack on that ground, we believe that a substantial possibility of its invalidity is raised with respect to FCM’s contention that the bank lacked an insurable interest. While we have not had the occasion to so rule, most courts apparently hold that an insurable interest may not be predicated on a contract which is void or unenforceable.1 FCM argues that the bank, by charging interest on the undisbursed portion of the proceeds of the mortgage note, exacted a usurious rate of interest, rendering the note and mortgage void, Minn. St. 334.03, and therefore lacked an insurable interest.

Our research has not uncovered a decision which involves the precise issue presented in this case — whether an insurable interest can arise out of a usurious mortgage. However, the decisions we have found which considered the broader issue of whether an insurable interest can arise out of a void or unenforceable contract persuade us that the answer to the question is that it cannot.

In Cherokee Foundries, Inc. v. Imperial Assur. Co. 188 Tenn. 349, 219 S. W. 2d 203 (1949), the Tennessee Supreme Court held that a purchaser of real property under an oral contract of sale, unexecuted at the time of the fire, lacked an insurable interest because the contract was. unenforceable under the statute of frauds. The court found:

“From the moment Cherokee Foundries applied for this in[199]*199surance to the moment of the next day when the parties were to meet at the bank and complete the transaction, it was a matter entirely within the whim and caprice of Cherokee Foundries as to whether it would pay the purchase price and take the property if the seller elected (a matter, too, entirely subject to its whim) to let the Cherokee Foundries have the property for the stated purchase price, or at all. Either could repudiate the oral agreement with impunity, because of the Statute of Frauds. Their status remaining the same, they could by mutual agreement just as easily have postponed the meeting at the bank for the completion of the transaction to any date less than twelve months after the Cherokee Foundries applied for this insurance, and upon the arrival of the day fixed, either party could have repudiated without resulting liability the oral contract upon which the insured here bases his right to recover the insurance.
“So, whether the insurance policy in question was a policy coupled with an interest was eventually dependent upon the whim of either the Cherokee Foundries or the seller.

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Phalen Park State Bank v. Reeves
251 N.W.2d 135 (Supreme Court of Minnesota, 1977)

Cite This Page — Counsel Stack

Bluebook (online)
251 N.W.2d 135, 312 Minn. 194, 1977 Minn. LEXIS 1628, Counsel Stack Legal Research, https://law.counselstack.com/opinion/phalen-park-state-bank-v-reeves-minn-1977.