The Employer's Liability Assurance Corporation, Limited v. L. J. Marcotte Insurance Agency, a Partnership, Etc.

314 F.2d 470
CourtCourt of Appeals for the Eighth Circuit
DecidedApril 1, 1963
Docket17108
StatusPublished
Cited by1 cases

This text of 314 F.2d 470 (The Employer's Liability Assurance Corporation, Limited v. L. J. Marcotte Insurance Agency, a Partnership, Etc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Employer's Liability Assurance Corporation, Limited v. L. J. Marcotte Insurance Agency, a Partnership, Etc., 314 F.2d 470 (8th Cir. 1963).

Opinion

SANBORN, Circuit Judge.

The Employers’ Liability Assurance Corporation, Limited (Employers), a foreign insurance company, as a subrogee and assignee of Mutual Benefit Health & Accident Association (Mutual) and United Benefit Life Insurance Company (United), both of Omaha, Nebraska, brought this diversity action on February 8, 1957, against L. J. Marcotte Insurance Agency (Marcotte Agency), a partnership, and its members to recover the amount of a loss suffered by Mutual and United which Employers, by the terms of an “Insurance Companies’ Blanket Bond” which it had issued to them, was obliged to pay. The Marcotte Agency was alleged to be liable for the loss, which had been occasioned by the dishonesty of an employee of the Agency in connection with the adjustment of claims on policies which it, as General Agent for Mutual and United, had written for those companies. The Marcotte Agency denied liability. The case was tried to the District Court, without a jury, upon a Stipulation of Facts and the evidence of two witnesses, one of whom was the Vice-President in charge of claims for Mutual and Claims Manager for United, and, the other, Robert D. Marcotte, one of the partners in the Marcotte Agency.

The District Court concluded “that the direction and control which Mutual and United exercised over the adjuster [the employee of the Marcotte Agency who had defrauded the companies] was of such a degree as to clearly preclude these companies from holding the Marcotte Agency responsible to them for the consequences of his actions.” Judgment was entered for the defendants, and the plaintiff has appealed.

It is unnecessary to state in complete detail the underlying facts. The most concise and easily understandable statement of how the loss came about is found in the sworn Proof of Loss dated October 1, 1956, submitted to Employers by Mutual and United. It reads as follows:

“It is hereby certified that the undersigned [Mutual and United] has sustained a loss through the dishonesty of Richard O. Channel employee of Marcotte Insurance Agency employed at said Marcotte Insurance Agency in the position of Claim Auditor.
“The circumstances and evidence of such loss are as follows: Richard *472 O. Channel, Claim Auditor at the Mareotte Insurance Agency of Omaha, Nebraska, representing Mutual Benefit Health and Accident Association and United Benefit Life Insurance Company, handled claims originating through this agency in its territory. In such position he was authorized to draw drafts against the Companies in payment of valid claims. From October, 1955 to June, 1956, Channel drew various drafts on the Companies in payment of claims. In some of these cases it has been found that Channel created false proofs in excess of the actual liability under valid claims. In other cases, he established false claims and proofs. Drafts issued by him under both situations were honored by the Companies, and the total amount of such drafts constitutes the amount of this claim. In the-case of each draft Channel forged the endorsement of the insured and. retained the proceeds personally.
“The dates and amounts of such loss are set forth in detail on the reverse hereof. * * * ”

The total loss aggregated $12,111.23.

The liability of the Mareotte Ageney -nd its members for this loss depends-, upon whether, under the law of Nebraska, they were answerable to Mutual and' United for the misdoings of the Agency’s-, employee Channel.

During the period in suit, the MarcotteAgency was a General Agent of MutuaL and United, and was authorized “to write-business through sub-agents” for those-companies.

So much of the Stipulation of Facts asi seems pertinent is set out in the margin. 1

*473 Mr. LeClair, Vice-President in charge <of claims for Mutual and Claims Manager for United, in his testimony described how policy claims against those companies were processed. After testifying ■that “Mr. Channel was Claim Auditor in the Marcotte Agency,” the following ■questions were asked Mr. LeClair, and '■the following answers given:

“By the Court: What do you mean by ‘Claim Auditor’?
“The Witness: Well, Mr. DeLacy [counsel for appellant] has referred to him as an adjuster. They are •claim payers. That is, they take the • claim and audit it. In other words, they check whether the diagnosis is covered by the policy, and then check to see what is payable under the terms of the policy in accordance with the claim.
“By the Court: And then draw a draft?
“The Witness: And then draw a draft. Mr. Channel would draw this draft, a copy of which must be sent immediately to the home office, together with the file, and the form 112, which I believe has been referred to in one of the exhibits here. Form 112 would show the nature of *474 the audit made of the claim by the adjuster or the auditor.
“The home office then reviewed that file which contained the proofs of loss bills, if there were bills, the form 112, and a copy of the draft. The check at the home office was made to see that the claim was payable, the policy was in force, that this particular claim came within the terms of the policy, and then that the amount paid was correct. If that were true, it was approved, and this in turn went into a section in our Claim Department for the making up of a stat card which, in effect, became our draft stub. The stat cards are then filed until the original draft comes through the Omaha National Bank and is delivered to us for payment.
“This is done each day, and we are required to cover all of those drafts within twenty-four hours by our check to the Omaha National Bank.
“That is the system we use.
“Q. Do you have many of these checks or drafts ? Do they run into numbers?
“A. 3500 a day, approximately, is average.”

Mr. Robert D. Marcotte, one of the partners in the Marcotte Agency, testified that Channel was trained for his work by Mutual and United at the time he was employed by the Agency, and before repox-ting to its office. Asked if he knew what the course consisted of, he answered:

“A. In a general way, it consisted of training in all the duties he would perforxn in our agency, auditing claims, paying claims; all the procedures that are set out in multiplicity in all of the procedural bulletins that the company has covering all these subjects.
“Q. That was all according to procedures and directives laid down by your insurance companies, Mutual and United?
“A. Absolutely. That is the only way we could operate.”

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Bluebook (online)
314 F.2d 470, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-employers-liability-assurance-corporation-limited-v-l-j-marcotte-ca8-1963.