Union Agricultural Society v. Anchor Fire Insurance

9 Ohio N.P. (n.s.) 49
CourtLorain County Court of Common Pleas
DecidedDecember 21, 1907
StatusPublished

This text of 9 Ohio N.P. (n.s.) 49 (Union Agricultural Society v. Anchor Fire Insurance) is published on Counsel Stack Legal Research, covering Lorain County Court of Common Pleas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Union Agricultural Society v. Anchor Fire Insurance, 9 Ohio N.P. (n.s.) 49 (Ohio Super. Ct. 1907).

Opinion

Washburn, J.

Heard on motion.for new trial.

This is an action brought by the plaintiff against the defendant to recover for a loss occasioned by fire under the terms and conditions of' a certain policy issued by the defendant to the plaintiff.

. The policy, as stated therein, covered insurance as follows: “$300 on frame, shingle roofed building, occupied as Floral Hall, situated on the east side of the Wellington Agricultural Society grounds,” and said policy contained the following condition:

“This entire policy, unless otherwise provided by agreement endorsed hereon or added hereto, shall be void * * * if the interest of the insured be other than unconditional and sole ownership.;, or if the subject of insurance be a building on ground not owned by the insured in fee simple.”" •

And also the following provision:

“This policy, is made and accepted subject to the foregoing stipulations and conditions, together with such other provisions, agreements, or conditions as may be- endorsed hereon or added hereto, and no officer, agent, or other representative of -this company shall have power to waive any provision or condition of the policy except such as by the terms of this policy may be subject of agreement indorsed hereon or added hereto, and as to such provisions and conditions no officer, agent, or representative shall have such power or be deemed or held to have waived such provisions or conditions unless such waiver, if any, shall be written upon or attached hereto, nor shall any privilege or permission affecting the insurance under -this policy exist or be claimed by the insured unless so written or attached.”

As a defense to the action the defendant pleaded the foregoing conditions and alleged that said plaintiff was.not the unconditional and sole owner of said property; nor did it own the ground upon which said building was situated, and for that reason said policy was null and void.

[51]*51In reply thereto the plaintiff alleged that at the time the policy of insurance was drawn up and delivered to the plaintiff the defendant well knew and fully understood that the land on which the building in question was insured ivas not owned in fee simple by the plaintiff, but that the plaintiff was the owner of a lease of the same for ninety-nine years; that fully understanding said facts the defendant itself drew up said policy and delivered .the same to the plaintiff, and that the plaintiff in'no wise misrepresented to or concealed said facts as to the ownership of said land or the interest of the plaintiff in said land from the defendant, and claimed that the defendant was estopped from setting up the claim that the plaintiff was not the unconditional and sole owner of the land on which the building in question was situated.

Upon the trial of the case plaintiff offered evidence tending to prove that the agent of the defendant who issued the policy knew at the time it was issued that the, building in question stood upon leased land and that the plaintiff was not the owner in fee simple of such land. Objection was made to this testimony, which -objection was overruled and exception noted.

The real ground of the objection was not stated to the court at the time of the trial, and the plaintiff’s claim appearing to be a meritorious one and the defense a highly technical one, the court, in the hope that there might be found some legal ground upon which to support this action, admitted the testimony, and the jury was instructed that if the company knew of the condition of the title” at the time the policy was issued that it was estopped to claim that condition as a defense, and the jury having found for the plaintiff, the question is now before the court upon a motion for a new trial.

Since said trial the court has had an “opportunity to make an investigation of the law on the subject that could not be made during the trial, and I have come to the conclusion that under the law as it is, no successful suit can be maintained on this policy, at least without reforming the policy, and by this remark I -do not mean to intimate that there was any evidence introduced at the trial which would warrant a reformation of the policy.

.It seems that in early times in this country insurance policies were construed strictly against the insurance company -and in [52]*52favor of the insured, on the theory that the policy was prepared by expert attorneys employed by the company and contained many restrictions and conditions printed in fine printing and in: such a manner as not to be readily understood by the insured, and many of the decisions sustaining recoveries on policies were rendered before the policies contained the condition last above referred to in reference to the authority of the agent to waive any of the conditions or provisions of the policy unless the waiver was 'in writing indorsed upon such policy. And even after such condition was contained in the policies it was held that such restrictions upon the power of the agent could not be.' deemed to apply to those conditions which related to the inception of the contract when it appeared that the agent had delivered the contract .and received the premiums with a full knowledge of the actual situation, and it was said that to take the benefit of a contract with full knowledge of all the facts and attempt after-wards to defeat it when called upon to perform, by asserting conditions relating to those facts, would be to claim that no contract was made and thus operate as a fraud upon the insured. That was the theory that I took of this ease when it was submitted. It seemed to me that if the insurance company knew that the property insured was upon leased ground and issued a policy stating that if it was upon leased ground the policy should be void, that it thereby issued a policy which it knew at the time of its issue was void and accepted pay therefor, and that such a transaction was a fraud upon the insured and that it was the duty of the court to relieve against such fraud.

■ But the later decisions, while recognizing the rule that ambiguous language in an insurance contract is to be construed against the company, détermine that “policies of insurance should be construed, like other contracts, so as to give effect to the intention and express language of the parties” (Travelers Ins. Co. v. Myers, 62 Ohio St., 529), and it has accordingly been held that where an insured accepts a policy he is thereby assumed to know of the terms of the contract contained therein and is bound by them to the same extent as if the contract had been discussed and all of its conditions had been carefully considered and agreed upon and then reduced to writing by the [53]*53parties and signed by them (Union Cent. Life Ins. Co. v. Hook, 62 Ohio St., 256), and by the great weight of authority it is held that parol evidence is not admissible to show that when the contract was entered into, the agent and the insured agreed upon other and different terms than those contained in, or indorsed upon, the policy, and that the knowledge of the agent of the company of facts which rendered the policy void when issued could not be received in evidence in an action at law upon a policy for the purpose of estopping the company from asserting the invalidity of the policy on grounds which the agent knew at the time of the issuing of the policy rendered the policy void.

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Cite This Page — Counsel Stack

Bluebook (online)
9 Ohio N.P. (n.s.) 49, Counsel Stack Legal Research, https://law.counselstack.com/opinion/union-agricultural-society-v-anchor-fire-insurance-ohctcompllorain-1907.