Houchens v. American Home Assurance Co.
United States Court of Appeals for the Fourth Circuit
927 F.2d 163 (1991)
- Written by Jamie Milne, JD
Facts
When Coulter Houchens received a week of vacation leave, he went on a trip to Thailand. He arrived in Bangkok on August 15, 1980, and was never seen or heard from again. Seven years later, Coulter’s wife, Alice Houchens (plaintiff), had a Virginia court declare Coulter presumed dead under state law. Alice then tried to collect life-insurance proceeds from American Home Assurance Co. (American) (defendant) based on either of two policies Coulter had with American, both of which were accidental-death policies. When American refused to pay, Alice sued American for breach of contract. American moved for summary judgment, arguing that it was not liable for payment because there was no evidence that Coulter died, let alone that his death was accidental. The district court granted American’s motion, and Alice appealed.
Rule of Law
Issue
Holding and Reasoning (Ervin, C.J.)
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