Snyder v. United Benefit Life Insurance

123 N.W.2d 234, 371 Mich. 36, 1963 Mich. LEXIS 284
CourtMichigan Supreme Court
DecidedSeptember 4, 1963
DocketCalendar 21, Docket 49,814
StatusPublished
Cited by11 cases

This text of 123 N.W.2d 234 (Snyder v. United Benefit Life Insurance) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Snyder v. United Benefit Life Insurance, 123 N.W.2d 234, 371 Mich. 36, 1963 Mich. LEXIS 284 (Mich. 1963).

Opinions

O’Hara, J.

Harold J. and Diana Snyder, plaintiffs, are the parents of Darrel Snyder, deceased. [37]*37He died November 19, 1960, of injuries sustained in an airplane crash which occurred November 13,1960. They are also named his beneficiaries in an application for a $25,000 life insurance policy directed to defendant company.

John S. McKenzie is a soliciting agent for defendant insurance company. In 1954, the agent sold a policy of life insurance to plaintiff father, and at various times in the period between that sale and September 20, 1960, he and the father discussed the prospect of selling additional policies covering the plaintiffs’ 2 sons, Duane and Darrel.

On September 20, 1960, agent McKenzie came to the Snyder home with a view to the sale of a life policy on Darrel. By this time Duane had applied for and received his policy.

At the home the evening of the visit were Darrel, his mother, plaintiff Diana, Hazel, his wife, now widow, his grandmother, and later his father, plaintiff Harold J. Snyder. The meeting took place in the family dining room.

■ It is the claim of the plaintiff that oral representa^ tions were made by the agent on diverse occasions, including the time at which a life policy was sold to deceased’s brother, and again on the night deceased signed his application, which were completely at variance with the printed application form. Specifically the form of the application contained the following questions — answered affirmatively but in the agent’s handwriting:

“And do you agree that the company is not bound by any statement made by or to any agent unless written herein * * * and do you further agree that there shall be no liability hereunder until a policy shall be issued, and delivered to and accepted by you while in good health and free from injury.”

[38]*38Plaintiffs contend, and support by testimony of deceased’s father and mother (over strenuous objection) and deceased’s wife, that the agent said in substance: “You are insured as soon as you have a medical examination and leave the medical examiner’s office a healthy man.” They further contend, and support by testimony, that a medical examination was made and a requisite urine specimen taken and analyzed. The examining physician testified he found the urine specimen negative, and that the physical examination disclosed nothing to disqualify deceased as an insurance risk. He additionally testified that he sent the completed medical examination blank and the urine specimen to the company home office at least a week before deceased sustained the injuries which caused his death 6 days later. The additional claim of plaintiff is that the agent did not show the application blank to deceased, nor read its provisions to him, but merely asked him questions to which he, the agent, wrote down the answers and only told deceased to sign the blank on the signature line. Plaintiffs assert their total reliance upon the agent’s alleged representations, to the exclusion of the application form. The total first annual premium was paid by the agent under an agreement with plaintiff-father that the agent would later be reimbursed therefor. Admittedly the agent fulfilled this commitment but was not reimbursed therefor until after deceased’s injury.

The declaration, in a single count, alleges actually somewhat contradictory theories. Paragraphs 5, 6, and 7 assert the agent’s representations, the reliance thereon, the satisfactory completion of the medical examination and urine test, and their “submission” to defendant by mail. Paragraphs 9 and 12 allege an unreasonable delay after receipt of the examination, the urine specimen and the first premium with [39]*39a consequent waiver of any conditions precedent to the effective coverage of the deceased.

Defendant contrariwise denies the authority of the agent to alter the terms of the contract and denies in fact that he made such representations. The company urges strenuously that assuming the agent made such representations, there was no reliance upon them by plaintiffs under their own testimony. It is the insurer’s further claim that the urine specimen was not in fact sent by the medical examiner on either date he asserts he sent it. There is a strong suggestion in their testimony that it was not sent until after deceased was injured and that the medical report was never sent — at least never received by it. The company denies any undue delay in processing the application for the reason that there was never in the office the precise item necessary to process the application. They emphasize that this aspect of the case formed no part of the claim in the declaration and that plaintiffs’ counsel affirmatively denied that such was a part of their claim — and further that the burden of establishing undue delay was plaintiffs’ and that such burden was not met.

On these controverted factual issues, the case was submitted to the jury under a general charge and the jury returned a verdict in the full amount of the unissued policy — $25,000.

It must be conceded that much, if not all, the force of plaintiffs’ first theory, or the first facet of their declared theory, was vitiated by their own testimony on cross-examination. Accepting the claim of plaintiffs that the application form was not read and that applicant did not see the 2 limiting provisions, namely, (1) “The company reserves the right to require medical examination of any applicant,” and (2) “Is applicant being examined? Yes,” plaintiff Harold Snyder still testified as follows:

[40]*40.. ' “Q. Now, you do know that certain things had to be done with respect to the examination, did you not, Mr.- Snyder?
“A. I figured there were.
“Q. And what were these things?
“A. Examination, for one.
“Q. And what else?
“A. A urine specimen.
“Q. And what would happen to that urine specimen?
“A. It would have to go to the home office.
“Q. And what would have to happen to the medical examination that was made?
“A. It would have to be approved.
“Q. At the home office; is that correct?
“A. Right.
“Q. Uh-huh, and the urine specimen also would have to be approved?
“A. Right.”

The coplaintiff testified in the same tenor with some semantic difficulty over the word “accepted”:

“Q. Now, referring to this nonmedical business. You realize that Duane, or that Darrel, would have to have a medical examination, did you not?
“A. That’s right.
“Q. And, as a matter of fact, you testified before that Mr. McKenzie gave you some medical papers; is that correct?
“A. He gave them to Darrel.
“Q. Well, gave them to Darrel, but you saw him give them; is that correct?
“A. That’s right.

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Snyder v. United Benefit Life Insurance
123 N.W.2d 234 (Michigan Supreme Court, 1963)

Cite This Page — Counsel Stack

Bluebook (online)
123 N.W.2d 234, 371 Mich. 36, 1963 Mich. LEXIS 284, Counsel Stack Legal Research, https://law.counselstack.com/opinion/snyder-v-united-benefit-life-insurance-mich-1963.