Sara Rosenberg v. PHL Variable Insurance Co

CourtCourt of Appeals for the Third Circuit
DecidedMay 7, 2024
Docket23-1234
StatusUnpublished

This text of Sara Rosenberg v. PHL Variable Insurance Co (Sara Rosenberg v. PHL Variable Insurance Co) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sara Rosenberg v. PHL Variable Insurance Co, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _____________

No. 23-1234 _____________

SARA ROSENBERG, AS TRUSTEE OF DOUGLAS ROSENBERG 2004 TRUST, Appellant

v.

PHL VARIABLE INSURANCE COMPANY; PHL DELAWARE, LLC; NASSAU INSURANCE GROUP HOLDINGS, L.P.; NASSAU FINANCIAL GROUP, L.P. _____________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. Civil No. 2-21-cv-02673) District Judge: Honorable Karen S. Marston _____________

Argued January 17, 2024

Before: HARDIMAN, MATEY, and PHIPPS, Circuit Judges

(Filed: May 7, 2024)

_____________

Michael Broadbent [ARGUED] Arianna K. McLaughlin Gabriella M. Scott Cozen O’Connor 1650 Market Street One Liberty Place, Suite 2800 Philadelphia, PA 19103 Counsel for Appellant Jarrett E. Ganer [ARGUED] Micah A. Grodin Jay M. Patterson McDowell Hetherington 1001 Fannin Street Suite 2400 Houston, TX 77002 Counsel for Appellees

OPINION * _____________

MATEY, Circuit Judge.

Sara Rosenberg, as trustee for the Douglas Rosenberg 2004 Trust, appeals from

the District Court’s grant of summary judgment for Appellees PHL Variable Insurance

Company, PHL Delaware, LLC, Nassau Insurance Group Holdings, L.P., and Nassau

Financial Group, L.P. (collectively, PHL Variable). 1 Because we agree that PHL Variable

was entitled to summary judgment on all claims, we will affirm.

I.

This is a dispute between an insurer and its insured over a life insurance policy.

* This disposition is not an opinion of the full Court and, pursuant to I.O.P. 5.7, does not constitute binding precedent. 1 Appellees PHL Delaware, LLC, Nassau Insurance Group Holdings, L.P., and Nassau Financial Group, L.P. “are holding companies that neither issued life insurance policies nor provided services or employees for PHL Variable.” App. 4. Appellant did not “contest their dismissal” below, App. 4, and the District Court entered summary judgment for these entities. We address only the claims asserted against PHL Variable.

2 A. The Trust Purchases a Term Life Policy from PHL Variable

In 2001, PHL Variable issued a $20 million term life insurance policy 2 on the life

of Maury Lane Rosenberg, the insured. The policy was owned by the Douglas Rosenberg

2004 Trust (the Trust). 3 The Trust was created for the benefit of Douglas Rosenberg, the

son of Maury Lane Rosenberg, the insured, and Sara Rosenberg, the sole trustee of the

Trust and Appellant here.

The life insurance policy had a 32-year term and was set to expire in 2033. In

addition to the benefit payable upon the insured’s death, the policy also provided the right

to convert it to “any whole life or any universal life insurance plan” that PHL Variable or

its affiliate companies “offer[ed] at the time of conversion.” 4 App. 197. This conversion

right was only available for the first twenty years 5 that the policy was in effect—that is,

2 In exchange for premiums, a term life insurance policy guarantees payment of a stated death benefit to the insured’s beneficiaries if the insured dies during the term of the policy. Life Insurance, Black’s Law Dictionary (11th ed. 2019). It is “not redeemable for a cash value during the insured’s life.” Id. 3 See also App. 5 n.2 (describing ownership history of policy). 4 The conversion could be accomplished “without evidence of insurability” to a “new [p]olicy on the life of the same insured under this [p]olicy but on a different plan of insurance.” App. 197. Unlike a term life insurance policy, both whole and universal life insurance policies are “permanent,” meaning that they last for the life of the insured. Compared to universal life policies, whole life policies “are more rigid and provide more certainty because they require fixed, periodic premiums be paid in exchange for fixed benefits and guaranteed cash value accumulation.” App. 6. Universal life policies, by contrast, are “more flexible but have less certainty because they allow the policyholder to vary the timing and amount of premiums and permit the insurer to periodically adjust the cost of insurance rates and credited interest rates that can impact the cash value accumulation and the amount of premiums needed to maintain coverage.” App. 6. 5 For the first twenty years that the policy was in effect, the annual premium was fixed at a rate of $68,675. The annual premium sharply increased in years 21 through 32, ranging from $2.1 to $5.9 million per year.

3 through 2021. During the relevant period, PHL Variable offered only one whole life

policy—Remembrance Life—and one universal life policy—PAUL IV—for conversion.

B. PHL Variable Stops Offering PAUL IV as a Conversion Option

In 2016, changes to the federal tax code and state regulations 6 impacted PHL

Variable’s ability to offer the PAUL IV universal life policy as a conversion option. As a

result, PHL Variable decided it could no longer offer PAUL IV after January 1, 2020, and

internal discussions in September 2019 focused on replacing it with Remembrance Life,

the whole life policy.

By October 2019, PHL Variable began including a specific warning on conversion

quotes for policyholders, including the Trust, that the “PAUL IV product will no longer

be available after [December 31, 2019] as a conversion option product.” App. 465.

Additionally, call center representatives 7 were instructed to tell “clients about the

6 The changes required that all life insurance contracts issued on or after January 1, 2020 be priced on the 2017 commissioners standard ordinary (CSO) mortality table. The CSO mortality table is used by life insurers to determine the probability that people of a certain age will die in any one year. The table is also used by life insurance companies to calculate reserve requirements—how much money must be held in reserve to pay future policy benefits based on the age of policyholders and their expected mortality. The 2017 CSO mortality table was the first update since the 2001 CSO mortality table and reflected “significant improvement in the mortality rates.” Am. Acad. of Actuaries & Soc’y of Actuaries, Report on the 2017 CSO and 2017 CSO Preferred Structure Table Development 3 (Oct. 2015), https://perma.cc/5448-FJ2G. The PAUL IV product offering—the universal life policy—was based on the 2001 CSO mortality table. As a result of these changes, PHL Variable determined that it did not have the “infrastructure needed to calculate” the new reserves required under the 2017 CSO mortality table for PAUL IV. App. 7. 7 Call center representatives were not responsible for providing quotes to policyholders for potential conversions; rather, they recorded the requests and transmitted them to PHL Variable’s conversion processing team, “which prepare[d] a written quote

4 upcoming changes,” but were not themselves supposed to discuss the specifics of the new

policy. App. 472. Then, beginning on January 1, 2020, PHL Variable discontinued PAUL

IV and only offered a whole life policy, Remembrance Life, as a conversion option.

C. The Trust Converts Part of the Policy to PAUL IV

In late 2019, before the regulatory changes went into effect and before the policy’s

2021 conversion deadline, the Trust began exploring conversion options. The Trust asked

for, and received, conversion quotes three times. 8

First, on November 15, 2019, PHL Variable provided the Trust with a quote to

convert the entire $20 million term life policy to PAUL IV. 9 Second, on December 9,

2019, Douglas Rosenberg called PHL Variable to request a conversion quote for $10

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Sara Rosenberg v. PHL Variable Insurance Co, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sara-rosenberg-v-phl-variable-insurance-co-ca3-2024.