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Contracts Keyed to Farnsworth
United States Life Insurance Company v. Wilson
Citation:
18 A.3d 110 (2011)Facts
Dr. John G. Griffith purchased a life insurance policy from US Life in 1998, with his wife Elizabeth Wilson as the primary beneficiary. The policy provided a $400,000 death benefit and a $250,000 accidental death benefit. AMAIA acted as the third-party administrator for US Life, responsible for billing and collecting premiums. Dr. Griffith elected to make semi-annual premium payments due on May 15 and November 15 each year. The policy contained a grace period provision allowing payment up to 31 days after the due date, and a reinstatement clause permitting reinstatement within 90 days of the due date of the unpaid premium. Dr. Griffith failed to pay the May 15, 2007 premium. AMAIA sent him a “REMINDER NOTICE” stating that to assure active coverage, payment must be received within 60 days from the due date. After this extended period passed, AMAIA sent a “LAPSE NOTICE” with instructions for reinstatement. On July 23, 2007, Dr. Griffith electronically directed his bank to pay the premium. The bank sent a check on July 25, which was delivered to AMAIA on July 30. Meanwhile, on July 28, Dr. Griffith was struck and killed by a car while on vacation. AMAIA rejected the payment on August 2, unaware of Dr. Griffith’s death. When Wilson submitted a claim for benefits, AMAIA denied it, stating the policy had lapsed.
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