Statement of the case
The case of Michigan Miller’s Mutual Insurance Company v. Janelle R Benfield (1998) appeared before the United States Court of Appeals, Eleventh Circuit. It was decided on the 4th May 1998 and presented before many judges including the Edmondson and Birch judges. Besides, circuit judges such as Fay were present, while Tampa and FL, John J. Pappas represented the plaintiff. The defendant was represented by Bobby Gene Freemon and Jr.; the investigators included Paul W. Burke and Farnham together with the International Association of Arson Investigators.
The suit concerned the liability of Michigan Millers Insurance Corporation to the Florida resident Janelle Benfield, an insured individual against property loss as a result of fire incidence. Millers appealed as the district court granted Mrs. Benfield a motion for directed verdict at the Millers. The latter claimed that Mrs. Benfield breached the contract with the insurance company. They also argued that the district court made a mistake during the determination of the case where they discovered that she was barred from receiving compensation because of her ex-husband who was her co-insured. (Carper 60).
Facts to the case
Mrs. Benfield had entered into an insurance contract with her at that moment husband Richard M. Benfield. The agreement was made with the Millers homeowner’s insurance providers to cover their home in Florida. The policy described the rights and obligations of both sides under the signed insurance contract vividly. There was a section in the approved plan that said about providing protection for the loss of personal property destroyed by fire. However, in this section, there were discussed some exclusions and conditions which limit the protection.
The Benfield residence was on fire on July 6th, 1992; thus, they sought for compensation from the Millers Company as agreed in the contract. At the time of the accident, Mrs. Benfield had a dispute with her husband. Their marital relationship was tense, and the husband had even left the residence. He had stayed out for an extended period and only returned in December, 1991. However, the relationship between the couple continued to be strained; each of them even kept separate bank account. They only stayed together for the sake of their daughter. The marital troubles made them put their house on sale in May 1992. Mrs. Benfield wanted her husband to drop claim on the house. Upon his refusal, she began making plans to move out. On the 1st of July 1992, Mrs. Benfield was physically assaulted by her spouse in their residence. When she reported the case, the man was arrested, but released later with a temporary restraining order not to return to their marital home. When the fire incident happened, Mrs. Benfield was away with her close friend Marion Sommers. She recalled having locked only the door knobs, but she did not lock the deadbolt locks. When the woman returned from her weekend stay, she noticed that the house looked different from the way it had looked before she left. She saw the dead bolt locks closed. Mrs. Benfield recalled opening the door and finding smoke in her dining area, so she resorted to calling the fire department. However, her friend Sommers had managed to extinguish the fire before the fire department arrived (Carper 60).
A lieutenant Kehoe from the fire department started examining the cause of the fire outbreak. He carefully checked the remnants of the dining room and claimed that the reasons for the fire were suspicious. He did not find any manipulated evidence from the fire scene. The Miller’s investigator William Buckley came three days afterwards to investigate the scene. He stated that that the fire was intentionally set. Mrs. Benfield’s belongings were damaged from the smoke emitted by the fire; thus, she filed an application for the replacement of the damaged goods. On the other hand, Mr. Benfield filed a claim to quit the residence and his involvement with the contents of the insurance contract. However, the woman rejected it.
On August 1993, the insurance company started a court case to determine their liability to Mrs. Benfield for the damages. She counterclaimed and alleged that the company had breached their contract with her, and thus, deceived her. Mrs. Benfield wanted her husband to be a defendant in the case arguing that he was a necessary party. She claimed that she suspected him of setting the fire since he was a heavy drinker and smoker. The Millers tried to amend their original statement where they asserted that the fire was intentionally set. However, this change was denied, and the case was to proceed with their initial complaint. Finally, the verdict was directed to the Millers on the claim that Mrs. Benfield had breached the contract provision.
The Millers fire investigator attempted to explain how he concluded on the cause of the fire during the trials. He stated that he did not manage to find any source of the fire ignition and thus made his conclusion. The investigator neither performed tests nor took any samples from the fire remnants. The district court granted a motion to Mrs. Benfield as a result of Buckley because the investigator lacked a reliable explanation for his judgement. Therefore, the district court issued a verdict de novo to the case. In their turn, the Millers argued that even if their fire investigator’s testimony was stricken, there still was the evidence that would attach Mrs. Benfield to the setting of the fire.
Under the Florida law, for the insurers to be able to deny coverage of their policies, they must find sufficient evidence to make the insured guilty. At the trial, the evidence was produced that Mrs. Benfield had troubles with her home. She even tried to lure her husband to leave their marital home to her. Thus, he woman was accused to have set the fire intentionally so that she would receive the massive settlement from the insurance company. The evidence showed that the dead bolts on the door were not the same as she had left them. However, she and her daughter were the only people who had the keys to the deadlocks. Besides, more facts to prove her guilt was discovered when she claimed to have left the house on Saturday only to come back on Monday and find the home in the blaze. The jury did not fully comprehend her whereabouts. Moreover, the items in the dining table had not been tampered with, and this showed that the cause of ignition must have been intentional. The fire department also reported that in their opinion, the reasons for the fire were intentional as it was impossible to find the source of the ignition (Lentini 13).
For Mrs. Benfield to be compensated, and her property recovered, she was obliged to comply fully with the conditions stipulated in the contract she had signed with the Millers. The latter contended that she had breached the contract by making a false statement during the fire investigation. There was ample evidence to prove that she intentionally misrepresented the facts to the insurance company in connection with the fire, violating her contract. Any insured person should not benefit from any fraud he or she makes (Ubelaker 40).
The Florida’s law of the innocent co-insured claims that they may recover under an insurance policy even in the instances where the loss was caused by their intentional acts unless the insurance contract states otherwise (Carper, 60). The law explicitly states that incase an insured suffers from loss of property covered in an insurance policy, the burden of replacement shifts to the insurer who determines if the cause of the loss is within the scope of the contract. The conflict between the two parties should be carefully addressed to attain maximum satisfaction and coverage of the insurance policy. The law places a great deal of importance to protect the insured from the imputation of wrongdoing by the insurer. However, the contract shall be void if the insured party concealed or committed fraud to misrepresent the information.