Aetna Life Insurance v. Moore
Headline: Life-insurance dispute: Court reverses verdict and orders a new trial, clarifying when written application answers and agent statements affect payment for a policy.
Holding:
- Reinforces that written application answers can void a life policy if materially false.
- Limits reliance on agents’ verbal statements not included in the written application.
- Requires careful jury instructions about materiality at retrial.
Summary
Background
A life insurance company issued a $6,000 policy on John A. Salgue after he completed a written application and medical exam. The application included statements that the answers were to be part of the contract and that only executive officers could bind the company. The application asked about prior insurance, physicians consulted, and heart disease. Evidence showed conflicting medical opinions, a prior application with another company that was not granted or was withdrawn, and that Salgue later died suddenly after exertion.
Reasoning
The central question was whether Salgue’s answers in the written application were part of the contract and whether any untrue answers could void the policy under Georgia law. The Court examined Georgia statutes and cases about whether representations are treated as warranties and whether materiality is for the court or jury to decide. It found error in the trial court’s long instructions and in refusing certain requested instructions about material misrepresentation and the effect of agent statements. The Court also noted the policy clause saying only executive officers could bind the company and that statements not in the written application should not be charged to the insurer.
Real world impact
The Court reversed the judgment for the policy claimant and ordered a new trial because of faulty instructions and legal errors. The decision emphasizes the importance of written application answers, the limited effect of verbal statements to agents, and careful jury instructions about whether false answers were material. The ruling is not a final decision on liability; the matter returns to trial for a fresh factual determination.
Dissents or concurrances
One Justice (Pitney) dissented from the Court’s judgment.
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