Boseman v. Connecticut General Life Insurance

Background

A Texas resident and employee of a Gulf Oil subsidiary sued a Connecticut insurance company for disability benefits under a group policy issued to the oil company in Pennsylvania. The policy required written notice of permanent disability during employment or within 60 days after it ended. The employee did not give that notice. Texas law then in force would make notice periods shorter than 90 days void. The federal district court applied Texas law and favored the employee, but the Court of Appeals applied Pennsylvania law and denied recovery; the Supreme Court reviewed which State’s law governs.

Reasoning

The Court framed the central question as whether Pennsylvania or Texas law governs the policy’s notice requirement. It found the contract was negotiated, issued, paid for, and delivered in Pennsylvania, and the policy itself declared Pennsylvania law would control. The insurer dealt only with the employer in Pennsylvania and had not written or delivered policies in Texas. The Court held the employee’s certificate delivered in Texas was merely evidence of coverage and not part of the contract. The employer’s acts in Texas were done for its own and its workers’ benefit, not as the insurer’s agent. For those reasons, Pennsylvania law governs and the 60‑day notice clause is valid; because the worker missed that deadline he could not recover.

Real world impact

This ruling confirms that a policy negotiated and issued elsewhere, and governed by its chosen law, controls disputes over contract terms. Employees who fail to meet such policy notice rules may lose claims, and delivery of a certificate in the employee’s State does not by itself change the governing law. The decision affirms the court of appeals’ judgment.