Sunday, December 22, 2013

United States v. Vigneau case brief

United States v. Vigneau case brief summary
187 F.2d 70 (1st Cir. 1999)

CASE SYNOPSIS
Appellant insurer challenged a decision of a United States district court, which rendered a judgment in favor of appellee beneficiary in connection with an action to recover the face amount of a life insurance policy. The insurer had previously denied the beneficiary full payment on the policy that had been issued to her husband.

CASE FACTS
The insured, the beneficiary's husband, was a military aviation officer. He applied for insurance coverage. The first proposed policy issued by the insurer was rejected, and the insured requested that the policy be rewritten to take out the aviation coverage. The revised policy contained an aviation clause that limited the insurer's liability. The insured was killed while engaged in flight, and the beneficiary sought the face amount of the policy. This action was brought when the insurer refused to pay. The insurer claimed that the insured and the beneficiary knew that there was no pilot coverage, but through mistake the insured and the insurer failed to revise the original application so as to expressly conform to the revised policy. Thus, the insurer sought reformation of the contract. The jury awarded the beneficiary the full amount of the policy.

DISCUSSION

  • On appeal, the court reversed and remanded. 
  • The insurer was entitled to have its plea of reformation heard and decided by the district court. 
  • The issue had not been tried, although the district court's judgment purported to adjudicate it. 
  • Because the insurer was not permitted to develop the issue of reformation, remand was required.

CONCLUSION
The court reversed the award granted in favor of the beneficiary in the action concerning coverage of a life insurance policy. The court remanded for further proceedings.

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