Levy v. West Coast Life Ins. Co.

Dist. Ct. did not err in dismissing plaintiffs-insurance beneficiaries’ action against defendant-insurance company, alleging that defendant breached terms of its life insurance policy by failing to pay plaintiffs $3 million in policy proceeds under circumstances where policyholder had failed to make premium payment five months prior to her death. Section 234(1) of Illinois Insurance Code prohibits insurers from canceling policy within 6 months after policyholder missed premium payment deadline unless insurer had given policyholder notice that met certain requirements set forth in section 234(1), and Notice that defendant gave to policyholder, which essentially tracked language set forth in section 234(1), gave policyholder adequate notice of consequences of nonpayment of premium that included cancellation of policy if premium had not been paid by certain date. Fact that relevant notice provisions appeared on back side of Notice sent to policyholder, or that Notice did not specify that payment could be made to agent did not require different result.