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Searle v. Allstate Life Ins. Co.

Supreme Court of California

April 4, 1985

L.A. No. 31703

Opinion

 [*429]  [**1310]  [***468]    Martin Searle died as a result of a self-inflicted gunshot wound to the head. Under the terms of his life insurance policy his beneficiary, Alice M. Searle, was precluded from recovering the full value of the policy if death resulted from "suicide, whether sane or insane." We address five questions: (1) Should we [****2]  reconsider the conclusions reached on a prior appeal in this action concerning the meaning and validity of that clause of the policy notwithstanding the rule of law of the case? (2) Is the policy clause valid and unambiguous? (3) Must the insurance carrier, in order to avoid liability on the policy, carry the burden of proving that the insured's act of self-destruction was intentional and not accidental? (4) If suicidal intent is proven, can the beneficiary nevertheless recover by demonstrating that the deceased was unable to understand the physical nature and consequences of his act? (5) Can the beneficiary recover by demonstrating that the deceased was unable to control his conduct and that the act therefore was the result of an irresistible impulse? As will appear below, we answer the first four questions in the affirmative and the fifth question in the negative.

In May 1975 Martin Searle was issued a life insurance policy in the face amount of $ 50,000 by defendant Allstate Life Insurance Company (Allstate).  [*430]  Plaintiff Alice Searle, Martin's second wife, was the named beneficiary. In accordance with the terms of the contract, Martin paid his monthly premiums.  [****3]  He had fully performed his monetary obligations to Allstate at the time of his death on March 13, 1976. He was then 37 years old.

Following Martin's death, Alice Searle (Searle) filed a claim with Allstate for payment on the policy. In reliance on the clause that excluded coverage for "suicide, whether sane or insane," within two years of the issuance of the policy, Allstate denied liability and refunded the premiums. Searle accepted the offer, though she later retendered the premiums. Allstate, however, refused the retender.

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38 Cal. 3d 425 *; 696 P.2d 1308 **; 212 Cal. Rptr. 466 ***; 1985 Cal. LEXIS 269 ****

ALICE M. SEARLE, Plaintiff and Appellant, v. ALLSTATE LIFE INSURANCE COMPANY, Defendant and Respondent

Prior History:  [****1]  Superior Court of San Diego County, No. 405535, Stevens Fargo, Judge. 1

Disposition: The judgment is reversed and the cause remanded for proceedings consistent with this opinion.

CORE TERMS

suicide, insane, sane, self-destruction, ambiguous, premiums, nonaccidental, coverage, sanity, kill, negate, adhesion, irresistible, destruction, accidental, deliberate, dictionary, modifier, impulse

Civil Procedure, Judgments, Preclusion of Judgments, Law of the Case, General Overview, Insurance Law, Life Insurance, Exclusions, Suicide, Business & Corporate Compliance, Contracts Law, Contract Conditions & Provisions, Conditions Subsequent, Evidence, Inferences & Presumptions, Claim, Contract & Practice Issues, Allocation, Burdens of Proof, Burdens of Proof, Discovery, Methods of Discovery, Stipulations, Jury Trials, Jury Instructions, Relevance, Relevant Evidence, Ultimate Burden of Persuasion