Young v. Columbus Life Insurance Company

CourtDistrict Court, S.D. Ohio
DecidedSeptember 30, 2025
Docket1:22-cv-00553
StatusUnknown

This text of Young v. Columbus Life Insurance Company (Young v. Columbus Life Insurance Company) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Young v. Columbus Life Insurance Company, (S.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

WILLIAM H. YOUNG, : : Plaintiff, : Case No. 1:22-cv-553 : vs. : Judge Jeffery P. Hopkins : COLUMBUS LIFE INSURANCE : COMPANY, : : Defendant.

OPINION AND ORDER

William H. Young (“Plaintiff”) filed this purported class action against Columbus Life Insurance Company (“Defendant”) alleging breach of contract (Counts I, II and III), conversion (Count IV), and declaratory relief (Count V). This case is before the Court on Defendant’s Motion to Dismiss (Doc. 20), Plaintiff’s Memorandum in Opposition (Doc. 25), and Defendant’s Reply (Doc. 26). For the reasons stated below, Defendant’s Motion (Doc. 20) is GRANTED IN PART and DENIED IN PART. I. BACKGROUND

Plaintiff purchased a flexible premium adjustable life insurance policy (“the Policy”) from Defendant in 1997. Compl., Doc. 1, ¶ 10. Unlike standard term life insurance, the Policy included both a death benefit and a savings or interest-bearing component, which could accumulate value over time. Id. ¶ 17. The Policy provided that the “Account Value” would be calculated as follows: The account value on the policy date shall be the first premium less the monthly deduction for the first policy month less the monthly expense charge shown on Page 3. In calculating this monthly deduction, the policy date is treated as the first monthly anniversary day. On each later monthly anniversary day, the account value shall be calculated as (1) plus (2) plus (3) minus (4) minus (5) where:

(1) is the account value on the preceding monthly anniversary day adjusted for any partial surrender. (2) is one month’s interest on item (1). (3) is all premiums (except the first payment which put this policy into effect) received since the preceding monthly anniversary day. (4) is the monthly deduction for the month following the monthly anniversary day. (5) is the monthly expense charge shown on Page 3 . . . .

Id. ¶ 18. The “monthly expense charge shown on Page 3,” i.e., number (5), was $7.00. Id. ¶ 28. The Policy also provided that the “monthly deduction,” i.e., number (4), was calculated as follows: Each monthly deduction on the monthly anniversary day consists of the cost of insurance plus the cost of additional benefits provided by the rider.

The cost of insurance for the insured is determined on a monthly basis. To determine such cost:

(1) Divide the Death Benefit at the beginning of the policy month by one plus the guaranteed monthly interest rate. (2) Subtract the account value at the beginning of the policy month (excluding the monthly deduction from its calculation). (3) Add the cost of additional benefits provided by the rider. (4) Divide the resulting number by 1000 to get the number of thousands of dollars of insurance. (5) Multiply by the cost of insurance rate as described in the Cost of Insurance Rates section.

The cost of insurance for benefits provided by riders will be determined in those riders.

Id. ¶ 24 (emphasis added).

The “Cost of Insurance Rate” section in the Policy further provided as follows: The monthly cost of insurance rates are shown on Page 6.1 The actual rates charged may be lower but those shown are the maximum that could be charged. Any change in the cost of insurance rates shown will have no effect on the cost of any insurance for any rider attached to this policy. Any change in the monthly cost of insurance rates charged will be on a nondiscriminatory basis toward any one insured and will apply to all insureds of the same age, sex, and classification whose policies have been in effect the same length of time, not to exceed the maximum rates shown on Page 6. The cost of insurance rates will be determined by us based on our expectations as to future mortality experience.

Id. ¶ 25 (emphasis added).

Plaintiff alleges that although these provisions in the Policy authorized Defendant to deduct a monthly cost of insurance charge from his Account Value, Defendant was required to: (1) calculate the cost of insurance charge using the cost of insurance rates, and (2) determine the cost of insurance rates by exclusive reference to Defendant’s expectations of future mortality experience. Id. ¶¶ 26, 27, 30. Defendant, however, allegedly used other, unauthorized factors, including, but not limited to, non-mortality-related expenses, when determining the cost of insurance rates. Id. ¶ 31. Plaintiff contends that although Defendant issued annual account statements showing the monthly cost of insurance deductions from his Account Value, the statements affirmatively concealed Defendant’s use of unauthorized factors to determine the cost of insurance rates that Defendant used to calculate his monthly cost of insurance. Id. ¶ 39. As a result, Plaintiff did not discover Defendant’s contractual breaches until he retained legal counsel in June 2022. Id. ¶ 40. In his Complaint, Plaintiff concedes that the at-issue Policy provisions authorized Defendant to deduct a $7.00 monthly expense charge from his Account Value. Id. ¶¶ 23, 28. But in his view, by allegedly using non-mortality-related expenses to determine the cost of

1 Page six of the Policy includes a “Table of Guaranteed Maximum Insurance Rates per Thousands of Dollars of Insurance Based on 1980 CSO Nonsmoker Mortality Table, Age Last Birthday” that generally demonstrates that monthly maximum cost of insurance rates increased as policy holders aged. insurance rates, and then by using those rates to calculate the monthly cost of insurance deductions, Defendant ultimately deducted from Plaintiff’s Account Value more than the $7.00 maximum monthly charge allowed by the Policy. Id. ¶¶ 61, 62. Beyond this, Plaintiff also alleges that because people are living longer, mortality

expectations have generally improved since the Policy was originally priced. Id. ¶ 66. Despite this, Plaintiff asserts that Defendant failed to reduce the cost of insurance rates—rates that should reflect Defendant’s evolving future mortality expectations—and that Defendant’s failure to reduce those rates resulted in higher monthly cost of insurance deductions. Id. ¶¶ 27, 66, 67. Plaintiff filed his Complaint on behalf of himself and a purported class of other similarly situated policy holders who purchased flexible premium adjustable life insurance policies from Defendant. He alleges that Defendant’s practices resulted in breaches of contract (Counts I, II, and III) and conversion (Count IV). He also alleges a separate claim for

declaratory relief (Count V). Defendant moves to dismiss all of Plaintiff’s claims. Doc. 20. The motion is fully briefed and ripe for adjudication. II. STANDARD OF REVIEW

A party may move to dismiss a complaint for “failure to state a claim upon which relief can be granted” under Rule 12(b)(6) of the Federal Rules of Civil Procedure. Fed. R. Civ. P. 12(b)(6). To survive a motion to dismiss, a complaint must include “only enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). This, however, requires “more than labels and conclusions [or] a formulaic recitation of the elements of a cause of action,” and the “[f]actual allegations must be enough to raise a right to relief above the speculative level.” Id. at 555. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

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Young v. Columbus Life Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/young-v-columbus-life-insurance-company-ohsd-2025.