Pacific Life Insurance Company v. Blevins, No. 23-2596 (8th Cir. 2024)
Annotate this CaseIn this case, the United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision that the Pacific Life Insurance Company did not owe benefits to Katie Blevins, the beneficiary of a life insurance policy taken out by her late fiancé, Dr. Travis Richardson. Richardson applied for a life insurance policy and paid the first month's premium three days before he died. He did not sign the received policy or any required amendments. Blevins claimed that the policy was in effect at the time of Richardson's death, despite the policy not being physically delivered or formally accepted. Blevins also brought claims of bad faith, promissory estoppel, and apparent authority against the insurance company. In its decision, the court stated the policy was clear in its conditions, which required physical delivery and acceptance before the policy was in force. The court found these conditions were not met, as the policy was neither delivered nor accepted by Richardson before his death. Therefore, no death benefit was owed. As a result, Blevins' bad faith claim was also dismissed, as the insurer could not have acted in bad faith if there was no obligation to pay out the policy.
Court Description: [Benton, Author, with Erickson, and Kobes, Circuit Judges] Civil case - Insurance. The district court properly interpreted the provisions of this insurance contract with respect to when the policy was in force; to be in force, the policy must have been delivered and accepted, and the district court did not err in concluding the policy was not delivered and accepted under the circumstances presented; under the provisions of the policy it was not constructively delivered to the insured and was never accepted by him; as a result, the policy was not in force when the insured died. [ February 07, 2024 ]
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