Stephen M. Trattner, as Personal Representative for the Estate of Sarah Lazer v. National Western Life Insurance Company

CourtDistrict Court, D. Maryland
DecidedJune 26, 2026
Docket8:24-cv-00151
StatusUnknown

This text of Stephen M. Trattner, as Personal Representative for the Estate of Sarah Lazer v. National Western Life Insurance Company (Stephen M. Trattner, as Personal Representative for the Estate of Sarah Lazer v. National Western Life Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Stephen M. Trattner, as Personal Representative for the Estate of Sarah Lazer v. National Western Life Insurance Company, (D. Md. 2026).

Opinion

UNITED STATES DISTRICTCOURT c DISTRICT OF MARYLAND vo STEPHEN M. TRATTNER, as Personal Representative for . the Estate of Sarah Lazer, . Plaintiff of ov. 7 |. Civil Action No. 24-0151-TDC NATIONAL WESTERN : LIFE INSURANCE COMPANY, _ . Defendant.

Plaintiff Stephen M. Trattner (“Trattner”), in his capacity as personal representative for the estate of his late daughter, Sarah Trattner Lazer (“Lazer”), has filed this civil action against

Defendant National Western Life Insurance Company (National Western”) in which he alleges a _ State law breach of contract claim arising out of National Western’s refusal to pay the death benefit . of a life insurance policy in Lazer’s name. The parties have filed Cross Motions for Summary

Judgment, which are fully briefed. Having reviewed the submitted materials, the Court finds that . no hearing is necessary. See D. Md. Local R. 105.6. For the. réasons set forth below, National

Western’s Motion will be GRANTED, and Trattner’s Motion will be DENIED. oo □□ BACKGROUND | □□ Relevant background of this case is set forth in this Court’s June 28, 2024 memorandum

opinion, which the Court incorporates by reference. See Trattner v. Nat'l W. Life Ins. Co., No. TDC-24-0151, 2024 WL 3237075; at *1-2 (D. Md. Tune 28, 2024). Additional facts relevant to the resolution of the pending Motions aie set forth below. a □

The Policy On July 20, 1984, Trattner’s father purchased from National Western a flexible premium

adjustable life insurance policy (“the Policy”) with a $100,000 death benefit on the life of Lazer, "who was then known as Sarah Trattner. Trattner’s father named Trattner as the owner of the Policy . and paid National Western an initial premium of $5,231.00. The Policy was issued with a planned, billable annual premium of $231.00 and had an anniversary date of July.20 each year. As to the “planned premium, the Policy stated that “[a}fter the initial payment is made, we will accept any amount of money given to us. . . at any time as premium while this policy is in force.” Joint Record (“J.R.”) 8, ECF No. 70. However, the only other premium payment ever sent to National - Western in relation to the Policy was a $231.00 payment by Lazer on July 19, 2012. . The Policy had an account balance, which was calculated each month as the sum of the previous month’s account balance, the interest earned on the previous account balance, and any □□

_ premiums received for that month; minus any monthly deduction for the Policy owed in relation to the prior month. The monthly deduction included the monthly cost of insurance, the monthly expense charge, and any charge for an increase in the face amount of the Policy. The Policy □ permittéd a partial surrender, through which an amount up to the cash value of the Policy would be paid to the policyowner and deducted from the account balance. The Policy also contained a provision referencing a grace period (“the Grace Period”), which stated that: - If the account balance less any policy loans and loan interest on the date immediately before a Monthly Anniversary day is insufficient to cover the monthly deduction for the month following such Monthly Anniversary day, a.grace period _of 61 days shall be allowed for the payment of at least enough premium to cover the monthly deductions. Notice of this premium will be mailed to the last known . address of the policyowner. The grace period will begin on the date of this notice. This premium shall be due on the Monthly Anniversary day and, if not paid within the grace period, all coverage under this policy will terminate without value at the

and of the 61 day period. Ifa claim by death during the grace period becomes □□□□ payable under the policy, any overdue monthly deductions will be deducted from the proceeds. _ Id. According to the Policy, it would terminate at the earliest of: 1. The date that we receive a written request from you to surrender the policy. □

2. The Policy Anniversary after the Insured’s 95th birthday. = 3. The Maturity Date of this policy. . 4. The date that the grace period ends without payment of a premium to cover the monthly deduction. . . 5. The date the insured dies. . : □

On January 27, 2012, National Western received a Policyowner’s Change Request from Trattner, who assigned ownership of the Policy to Lazer. Lazer provided an address of record of 1220 Blair Mill Road, Apt. 903, Silver Spring, Maryland 20910. After this ownership change

request, Lazer remained the policyowner until her death. ° . □□

In August 2014, after receiving a United States Postal Service USPS”) returned mail □ notice from Lazer’s old address, National Western updated Lazer’s address of record to 101 King Farm Boulevard, Apt. D207, Rockville, Maryland 20850. By April 2015, the Policy had an account balance of $20,429. In May 2015, Lazer. requested a partial surrender of the Policy in the amount of $20,000, which National Western sent to Lazer in the form of a check dated June 9, 2015. After the partial surrender, the Policy’s account balance decreased to $446.72 as of July. 20, 2015. Prior to the partial surrender, the interest earned on the Policy’s account balance was greater than the Policy’s monthly deductions, such that the account balance grew each month. However, after the partial surrender, this was no longer true, □ and the monthly deductions began to reduce the Policy’s account balance during the period from

2015 to June 2018. Indeed, in the Annual Statements mailed to Lazer during this period, National Western stated that “if no further premium payments are made.. based’on the current rate of interest and cost of insurance, coverage will cease in.Sep[tember] 2018.” JR. 22, 24, 26,

In July 2018, the Policy’s account balance was $9.28, which was insufficient to cover the ©

Policy’s monthly deductions for the preceding month. On Tuly 20, 2018, National Western sent three documents to Lazer’s King Farm Boulevard address. The first was a “Notice of Premium which stated that the Policy’s $231.00 annual premium was due, which aligned with the Policy’s anniversary date. J.R. 34. The second was a “Notice of Past Due Premium,” which stated that: - The account balance on your policy is insufficient to pay the premium that was due - 06/20/2018. If an ‘additional payment is not received by.09/20/18, your policy will . lapse. This minimum amount must be received in our office by 09/10/18 to allow for processing.

. The payment required to pay this past due premium and keep your policy from lapsing is $231.00. Any automatic method of payment will continue during the grace period. 33. The third was a letter which stated, “We have recently sent you a premium notice advising

_ you that an additional premium, payment is required to keep your policy in force. Since your current premium payment may be insufficient to keep your policy in force, we would recommend that you contact our office regarding this problem.” J.R. 35. Following the issuance of these documents, Lazer did not remit any premiums to National Western or otherwise contact National Western.’ . . : Unbeknownst to National Western, Lazer stopped residing at the King Farm Boulevard address at some time before. July 20, 2018. National Wester discovered this fact in September .

2018, when it received a USPS notice stating that Lazer no longer resided at, that address. On

oe a

September 6, 2018, National Western obtained a consumer verification report for Lazer showing her new address as 635 Azalea Drive, Rockville, Maryland 20850. There is no evidence that Lazer ever informed National Western of this address change. On September 20, 2018, National Western mailed to Lazer at the Azalea Drive address a “Notice of Lapsed Policy” which stated: "DANGER | YOUR POLICY HAS LAPSED because the premium was not paid ' STOP AND THINK. J.R. 41.

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Stephen M. Trattner, as Personal Representative for the Estate of Sarah Lazer v. National Western Life Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stephen-m-trattner-as-personal-representative-for-the-estate-of-sarah-mdd-2026.