Prudential Ins. Co. of America v. Moore

Background

A man named John Andrew Salgue applied for a $5,000 life insurance policy and signed forms warranting that his answers were true. He said he was in good health, denied serious illness, and answered questions about other applications and prior declinations. Evidence at trial suggested these statements were untrue, including other pending applications and medical conditions the company was not told about.

Reasoning

The core question was whether Salgue’s answers were untrue and material enough to void the policy under Georgia law. The trial judge told the jury to consider Salgue’s honesty and intent. The insurer asked the court to give a specific instruction saying a prior decline by another company made the applicant’s answer false and would bar recovery. The Supreme Court found the trial court erred in refusing that request, concluded some answers were not true and were material under the Georgia code, and rejected the idea that an agent’s knowledge could alter the written policy terms.

Real world impact

The ruling sends the case back for a new trial and underscores that written application warranties matter. If an applicant’s answers are untrue and would change the insurer’s assessment of risk, the insurer can rely on that to resist payment. The decision also supports strict enforcement of the policy’s written terms over any informal agent statements.

Dissents or concurrances

Justice Pitney dissented, indicating at least one Justice disagreed with the majority’s conclusion to reverse and order a new trial.