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Eckenrode v. Life of America Insurance Company

United States Court of Appeals for the Seventh Circuit
470 F.2d 1 (1972)


Facts

In September 1967, Life of America Insurance Company (Life of America) (defendant) issued a life-insurance policy covering the husband of Eckenrode (plaintiff) in the event of his accidental death. The policy was for $5,000, payable immediately upon proof of death. In December 1967, Eckenrode’s husband died in a homicide, leaving her with several children and no assets. Although Eckenrode met the policy’s requirements for payment, Life of America refused to pay her the policy’s proceeds. Life of America had no basis for doubting the validity of Eckenrode’s claim, but still acted as if there were unresolved details surrounding her husband’s death. Denied payment, Eckenrode was forced to borrow money and rely upon relatives for her family’s support. In January 1968, Life of America sent a letter to Eckenrode that implied its payout was contingent on the completion of an ongoing police investigation and urged her to settle immediately for less than the value of her husband’s policy. Eckenrode brought suit against Life of America for the intentional infliction of emotional distress. The district court dismissed her suit. Eckenrode appealed.

Rule of Law

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Issue

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Holding and Reasoning (Kiley, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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