Crum v. Jackson National Life Ins. Co.
Annotate this CaseThe United States Court of Appeals for the Eleventh Circuit certified questions of Georgia law to the Georgia Supreme Court about life-insurance law. The basic question for the Supreme Court was whether a person could legally take out an insurance policy on his own life with the intent to turn around and sell that policy to a third party who had no “insurable interest” in the policyholder’s life. The person seeking to recover on the life-insurance policy in this case said that such a policy was legal if a third party was not involved in causing the policy to be procured. The insurance company says that with or without such third-party involvement, such a policy was an illegal wagering contract and therefore void, relying on some Georgia case law. But as it turned out, that case law was interpreting and applying old statutes. In 1960, the Georgia General Assembly repealed those statutes and replaced them with new statutory language that codified some, but not all, of the old decisional law, and the new language did not even hint at the unilateral-intent-based limitation that the insurance company advanced. So the Supreme Court answered the certified questions: under Georgia law, a life-insurance policy taken out by the insured on his own life with the intent to sell the policy to a third party with no insurable interest, but without a third party’s involvement when the policy was procured, was not void as an illegal wagering contract.
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