Postal Life Insurance v. Harmeyer

15 Ohio N.P. (n.s.) 476
CourtOhio Superior Court, Cincinnati
DecidedDecember 17, 1913
StatusPublished

This text of 15 Ohio N.P. (n.s.) 476 (Postal Life Insurance v. Harmeyer) is published on Counsel Stack Legal Research, covering Ohio Superior Court, Cincinnati primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Postal Life Insurance v. Harmeyer, 15 Ohio N.P. (n.s.) 476 (Ohio Super. Ct. 1913).

Opinion

Oppenheimer, J.

On April 27th, 1896, the Provident Savings Life Assurance Society of New York issued its policy of insurance in the sum of $5,000 upon the life of A.dolph F. Schmidt. The policy contained the following condition:

“Any assignment of this policy must be in writing, and a duplicate thereof must be furnished the society. Any claim arising under an assignment shall be subject to satisfactory proof of insurable interest existing at the death of the insured, or at the date of such claim if prior thereto, and the society shall [477]*477be liable to the assignee to the extent of that interest only; bnt the society will not assume ‘any responsibility for the validity of an assignment. ’ ’

The policy was payable to the estate of the insured. The annual premium of $88.80 was paid by the insured from April, 1896, until April, 1910, when the policy was assigned to Horace W. Harmeyer by a contract which reads as follows:

“ For value received I hereby assign and transfer unto Horace W. Harmeyer, No. 519 Main street, Room 208, Lincoln Inn Court, in the city of Cincinnati, State of Ohio, Policy of Insurance No. 76203 issued by the Provident Savings Life Assurance Society of New York upon the life of Adolph F. Schmidt of Cincinnati, Ohio, and duly reinsured in the Postal Life Insurance Company, all dividends, benefits and advantages to be had or derived therefrom, subject to the conditions of the said policy and to the rules and regulations of the company, and subject and subordinate to any indebtedness to the company.
“It is expressly agreed that before any payment shall be made by virtue of this assignment, satisfactory proofs of the insurable interest of the assignee shall be furnished to the company, and the company shall not be liable for any sum in excess of such insurable interest.
“Witness my hand and seal, at Cincinnati,• Ohio, this 22nd day of April, 1911.
“(Signed) Adolph F. Schmidt"

By a supplementary agreement on the reverse side of the aforementioned assignment, the insured endeavored to have Horace W. Harmeyer designated as beneficiary under said policy, but the company refused to allow this to be done as Harmeyer had no insurable interest in the life of the insured.' It is admitted by Harmeyer, and his correspondence corroborates this, that at the time when he received the policy from Schmidt he bad absolutely no insurable interest in Schmidt’s life, and Schmidt was not indebted to him in any sum whatsoever. He took the policy merely because, in his opinion, Schmidt was unwise in discontinuing it, and it was a profitable speculation for him to continue it in force.

The premiums on the policy, after the date of said assignment, were paid by Harmeyer until April of the present year, as was [478]*478also the interest on a loan of $485, which the insured had obtained from the company on said policy while it was still in his possession. On July 26th, 1913, Adolph Schmidt died leaving a widow, Carrie Schmidt, who has since qualified as administratrix of his estate in the probate court of this county, and one minor child. Immediately after- the death of the .insured, H'armeyer presented his claim and furnished proofs of death to the Postal Life Insurance Company. The company requested him to furnish some evidence of his insurable interest, stating that, as he held only a conditional assignment, it was necessary for him to indicate either that he had such insurable interest, or that the decedent had been indebted to him in an amount equal to or greater than the amount due under the policy. A great deal of correspondence between the company and Harmeyer ensued, which, on Harmejmr’s part, is in the opinion of the court decidedly unique. It consists largely of a refusal to comply with the request of the company, and of abuse of the company itself and of others whose names were not in any way involved in the transaction. The request made by the company was designated as “ridiculous,” the names appended to communications from the company were burlesqued and corrupted, and the solvency of the company was attacked. Despite the assurance of the company that its delay in payment was due only to Harmeyer’s refusal to furnish the necessary proofs and affidavits, and despite its assurance that the claim would be paid forthwith upon the furnishing of a release from the administratrix of the decedent’s estate, or necessary proofs of insurable interest, Harmeyer resorted to every possible method to embarrass the company and to force it to pay the money to’ him despite the propriety of the requests which had been made of him. He wrote to the superintendent of insurance for the state of New York alleging that he had complied with every requirement of the company, but that it had entirely ignored his communications, and declined to pay his claim, and accusing officials of the company of being tricksters who were purposely withholding payment from him. He also wrote to the post office inspector accusing defendants of using the mails with intent to defraud and alleging that stories were in circulation that the [479]*479company was totally insolvent and that it was its practice to refuse the payment of claims. In addition thereto he inserted advertisements in the local newspapers alleging that the company had unjustly refused to pay his claim, and' that he would be glad to hear from others who' had similar claims against the company which had not been paid.

During all this time the company wrote letters, which were decidedly moderate in tone, reiterating its previous statements and assuring Harmeyer that his claim would be paid as soon as he had complied with its reasonable demands, but that until he did so, it could not pay his claim without subjecting itself to a liability to Schmidt’s estate upon the same policy; but as a result of the unjust, and improper publicity which Harmeyer was giving it, the company filed this suit interpleading Harmeyer and the administratrix of Schmidt’s estate and paid the money into court and was discharged from all liability. It is Harmeyer’s contention that under the law of this state the assignee of a life insurance policy is not required to have an insurable interest in the life of his assignor; therefore the company’s request was unreasonble and improper, and he was justified in taking such steps as he saw fit in order to force the company to pay the money to him. This claim is by no means supported by the authorities. It is true that in a majority of jurisdictions the assignment of a life insurance policy to one having no insurable interest, where the assignment is not made by way of cover for a wager policy, is permissible. This rule obtains in this state (Eckel v. Renner, 41 O. S., 232, approved and followed in Keckly et al v. Coshocton Glass Company, 86 O. S., 213). The rule also obtains in Arkansas, Connecticut, Illinois, Indiana, Iowa, Massachusetts, Mississippi, Maryland, Michigan, Nebraska, New Hampshire, New York, Rhode Island, South Carolina, Tennessee, Wisconsin and Vermont. The Supreme Court of the United States at first denied the validity of such assignments (Cammack v. Lewis, 15 Wallace, 643; Warnock v. Davis, 104 U. S., 775). But it is since held that such assignment is valid, and now seems to be in accord with the weight of authority. Insurance Company v. Armstrong, 117 U. S., 591.

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Related

Page v. Burnstine
102 U.S. 664 (Supreme Court, 1881)
Warnock v. Davis
104 U.S. 775 (Supreme Court, 1882)
New York Mutual Life Insurance v. Armstrong
117 U.S. 591 (Supreme Court, 1886)

Cite This Page — Counsel Stack

Bluebook (online)
15 Ohio N.P. (n.s.) 476, Counsel Stack Legal Research, https://law.counselstack.com/opinion/postal-life-insurance-v-harmeyer-ohsuperctcinci-1913.