Robinson v. Prudential Insurance Co. of America

776 N.E.2d 458, 56 Mass. App. Ct. 244, 2002 Mass. App. LEXIS 1263
CourtMassachusetts Appeals Court
DecidedOctober 11, 2002
DocketNo. 00-P-374
StatusPublished
Cited by5 cases

This text of 776 N.E.2d 458 (Robinson v. Prudential Insurance Co. of America) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robinson v. Prudential Insurance Co. of America, 776 N.E.2d 458, 56 Mass. App. Ct. 244, 2002 Mass. App. LEXIS 1263 (Mass. Ct. App. 2002).

Opinion

Dreben, J.

This is an action by a widow against an insurer and its sales agent to recover death benefits under a life insurance policy issued to the widow’s husband, Russell Robinson (Russell). The insurer, Prudential Insurance Company of America (Prudential), declined to pay the benefits, claiming that Russell had misrepresented the state of his health in applying for the policy. A judge of the Superior Court granted summary judgment for the defendants. Whether that grant was proper depends in large part on which of two sections of G. L. c. 175 applies, § 124 or § 186, and that, in turn, depends on whether the policy issued “without previous medical examination.” The two sections are set forth in the margin.2 We hold that the term “medical examination” contained in § 124 refers to an examination by a physician and does not include an examination by a nurse, and that the question whether the insured’s statements were “wilfully false, fraudulent or misleading,” as required by § 124, presents a jury issue. Accordingly, we reverse the judgment for the insurer.

We first set forth the legal significance of a medical examination and then describe the facts, viewed in the light most favorable to the nonmoving party. Sullivan v. Brookline, 435 Mass. 353, 356 (2001).

[246]*2461. Significance of “medical examination.” The importance of determining whether the examination of Russell by a nurse was a “medical” one within the meaning of G. L. c. 175, § 124, is explained in Protective Life Ins. Co. v. Sullivan, 425 Mass. 615, 623 (1997), and in Torres v. Fidelity & Guar. Life Ins. Co., 34 Mass. App. Ct. 376, 377-380 (1993). As seen from its legislative history, the purpose of § 124 is to impose a higher burden of proof on an insurer when it contests a life insurance policy issued without a medical examination than when it contests a life insurance policy issued after a medical examination. Protective Life Ins. Co. v. Sullivan, 425 Mass. at 623. If there is an examination, § 186 applies, and an insurer need only show that the misrepresentation was made with an “actual intent to deceive” or that the misrepresentation “increased the risk of loss.” If a policy is issued without a medical examination, the insurer must show that the “statements were wilfully false, fraudulent or misleading.” G. L. c. 175, § 124.

2. Factual material submitted by the parties. According to the plaintiff’s affidavit, Louis Pumphrey, an insurance agent employed by the defendant, met with the plaintiff and Russell in November, 1997, in order to sell them a life insurance policy. Pumphrey asked Russell a series of questions about his health and medical history. In response, Russell told Pumphrey that he had high blood pressure and that he had suffered a stroke that had led to his hospitalization ten years earlier. Pumphrey returned several days later, met again with the plaintiff and Russell, and informed them that Russell need not submit to a medical examination but would have to give a urine sample and have his blood pressure tested.

Subsequently, in early December, a registered nurse, Elaine Whitman, came to their house, took Russell’s blood pressure and collected a urine sample. A week later, they received a letter from Pumphrey confirming life insurance coverage in the amount of $60,000. Pumphrey again met with the couple on January 8, 1998, handed Russell a typewritten application, and advised him that it had been completed in accordance with the information Russell had provided during the first meeting. Pum-phrey instructed Russell to sign his name where indicated on the final page of the application, and Russell did so without [247]*247fully reading the application. Russell died due to massive heart failure on April 3, 1998.

The insurance company supported its motion for summary judgment with affidavits stating that the responsibility for interviewing clients concerning their medical history lies with Prudential underwriters, rather than with agents. It is the underwriters who call clients on the telephone, ask medical questions, and determine whether medical examinations are necessary. On December 3, 1997, Prudential underwriter Vicky Fesmire spoke to Russell by telephone, asked him questions, and entered his answers on the application part of the insurance policy.

Since Russell had died during the two-year period before the policy had become incontestible, see G. L. c. 175, § 132, the insurer conducted an investigation after Russell’s death. Several answers on the application turned out to be incorrect and, had the insurer had the correct information, a higher premium would have been charged. The most important errors were negative answers to the following questions:

“(4) Has anyone proposed for coverage had:
“a. chest pain, or any disorder of the heart or blood vessels? . . .
“h. any disorder of the brain or nervous system?”3

The application prepared by Fesmire reflected Russell’s disclosure to her of his high blood pressure and contained details as to when it had been diagnosed and what had been prescribed.

Fesmire’s affidavit states that because of Russell’s age and the amount of the policy a medical examination was required. The policy, however, states that no medical examination is required. Fesmire claims this was a “typographical error,” and that Elaine Whitman, a registered nurse, performed the medical examination at the request of Prudential.

[248]*2483. Examination by Nurse Whitman. The form filled out by Whitman, entitled “Modified Examination Form,”4 consists of two pages: the first page contains (1) the name and social security number of the insured; (2) the name and date of birth of the person to be examined; (3) the name, social security number, address, and tax number of the examiner; (4) the date of the examination, amount of insurance, and name of the agent; and (5) a fee section to be completed by the examining physician relating to the services provided.5 The first page was filled out, except for the fee section.

Whitman completed a portion of the second page of the modified examination form: where and when the examination was done (at home at 6:00 p.m.); the current age or age at death; and year and cause of death of the insured’s family members (father, mother, brothers, sisters). The only physical examination performed by Whitman was measuring the insured’s weight and height, taking two readings of the insured.’s blood pressure, and taking a single reading of the insured’s pulse rate per minute. She wrote that she had mailed a urine sample and that there was no albumin or sugar in the insured’s urine. With a check-mark, she noted that Russell was not her patient and that she had no information regarding any physical or mental impairment that Russell might have. She left blank the parts of the form that asked whether there were any abnormalities of the eyes, blood vessels, respiratory organs, abdominal organs, or nervous system. Also left blank was a section instructing the examiner to “[e]xamine heart in upright, recumbent and [illegible] lateral recumbent positions” and asking whether there-were “murmurs.” Whitman signed the second page of the form.

4. “Medical examination” within meaning of § 124.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hejinian v. General American Life Insurance
22 Mass. L. Rptr. 684 (Massachusetts Superior Court, 2007)
Gray v. Fidelity & Guaranty Life Insurance
21 Mass. L. Rptr. 649 (Massachusetts Superior Court, 2006)
Palmer v. Youth Opportunities Upheld, Inc.
18 Mass. L. Rptr. 339 (Massachusetts Superior Court, 2004)
Palmer v. Youth Opportunites Upheld, Inc.
18 Mass. L. Rptr. 301 (Massachusetts Superior Court, 2004)

Cite This Page — Counsel Stack

Bluebook (online)
776 N.E.2d 458, 56 Mass. App. Ct. 244, 2002 Mass. App. LEXIS 1263, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robinson-v-prudential-insurance-co-of-america-massappct-2002.