Shapley v. Centurion Life Ins Co
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William Shapley appealed the district court’s dismissal of his breach of contract and negligence claims against Centurion Life Insurance Company and Wells Fargo Financial. Shapley and his wife applied for credit life insurance with Centurion on the same day they closed on a real estate loan with Wells Fargo. The Shapleys were provided with a notice of insurance underwriting practices. The application papers stated that the Shapleys would receive insurance coverage only if Centurion approved their application. Centurion never had a chance to have a phone interview with Mrs. Shapley (a requirement for the policy). The day after the Shapleys closed on their loan, Mrs. Shapley suffered a brain hemorrhage from which she died four days later. Mr. Shapley contacted Centurion the same day to claim benefits in connection with Mrs. Shapley’s passing. Centurion denied the claim because it never issued an insurance policy on Mrs. Shapley. Because the interview never took place, Centurion issued insurance solely to Mr. Shapley. Mr. Shapley argued on appeal that the district court's dismissal was in error. Upon review, the Supreme Court affirmed the district court’s decisions, finding that while the district court incorrectly concluded that there must be a contract for estoppel to apply, the denial of Mr. Shapley’s motion to amend was appropriate because his estoppel claim was futile.
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