Robert Whitmire v. Southern Farm Bureau Life Insurance Company, No. 21-1643 (4th Cir. 2022)
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Southern Farm Bureau Life Insurance Company (“Farm Bureau”) issued a term life insurance policy to S.M. S.M.’s husband, Plaintiff, who was the policy’s primary beneficiary. Farm Bureau received a notification from the Post Office indicating that S.M.’s address had changed. Farm Bureau sent its semiannual bill to S.M. at her South Carolina address, informing her that her payment was due on November 23, 2016. S.M. did not pay the bill. Plaintiff sued Farm Bureau in federal district court, seeking the policy’s coverage amount as well as excess damages for alleged unfair and deceptive trade practices on the part of Farm Bureau. He argued that Farm Bureau had not complied with a statutory notice requirement prior to canceling the insurance policy for nonpayment and he was therefore entitled to the policy’s benefits. The parties filed cross-motions for summary judgment, and the district court granted summary judgment to Farm Bureau.
The Fourth Circuit affirmed finding that Farm Bureau complied with the statute’s notice requirement. The court wrote that a literal interpretation of the statute’s language—referring to a notice being sent to the “last known post-office address in this State”—would not put S.M. on notice at all. Rather it would have Farm Bureau send “notice” to an address where it knows she no longer resides. Additionally, there is substance in Farm Bureau’s argument that a rigidly literal reading of the words “in this State” would require insurers to implement burdensome and nonsensical notice policies.
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