Crawford v. Equitable Life Assurance Society of the United States

Harvey Crawford (plaintiff) was the president of Crawford Heating and Cooling Company. The company was part of an association that contracted for a group life-insurance policy from Equitable Life Assurance Society of the United States (Equitable Life) (defendant). The policy provided life insurance for company employees. To be eligible for coverage, the employees had to work at least 32 hours weekly. In December 1964, Crawford submitted group life insurance enrollment forms for himself and his wife. In the enrollment form for his wife, Crawford made a representation that his wife was an employee of his company. Crawford’s wife filled out the accompanying application for life insurance and she represented that she worked at least 32 hours weekly for Crawford’s company as the secretary-treasurer. Equitable Life then issued a certificate of insurance on the life of Crawford’s wife. The certificate named Crawford as the policy beneficiary and provided insurance coverage according to the master group life-insurance policy. The master policy had an incontestability clause that precluded Equitable Life from challenging the validity of the policy once the policy had been in effect for two years. About four years after Equitable Life issued the certificate, Crawford’s wife died. The death certificate showed that the occupation of Crawford’s wife was a housewife. Equitable Life then called Crawford’s company to confirm that Crawford’s wife was a company employee. Equitable Life learned that Crawford was not a company employee. As a result, Equitable Life declined to pay the life-insurance proceeds. Crawford sued Equitable Life for payment of the proceeds. The trial court entered summary judgment in favor of Crawford, and the intermediate appellate court affirmed the trial court’s decision. Equitable Life appealed.