Sinkfield v. State Farm Insurance

Summarized by Laura Bartell , Wayne State University Law School
11 years 5 months ago

Citation:

No. 13-2587 (6th Cir. Sept. 5, 2014)

Tag(s):

Ruling:

Affirming grant of summary judgment by district court for the E.D. Mich., the Court of Appeals held that defendant insurer did not breach a contract for insurance when it denied plaintiff's claim, because plaintiff fraudulently misstated the value of plaintiff's property.

Procedural context:

Plaintiff filed a claim for losses incurred when her house burned down. Defendant insurer denied the claim on the basis of the policy's fraud clause. When plaintiff sued, the district court granted summary judgment in favor of the insurer and plaintiff appealed.

Facts:

Plaintiff purchased a home for $50,000 in 2010, and obtained a $200,000 insurance policy on the home from defendant. Shortly thereafter plaintiff filed for chapter 7 bankruptcy protection. Although plaintiff originally claimed that her house was worthless, she later amended her petition to claim that her house was worth $27,000. She also claimed total assets of $4,000. She was discharged in April 2011 with her creditors receiving nothing. Less than fourteen months later, her house burned down and she filed a claim for $143,000 in damage to the house, and loss of $170,000 in personal property. Plaintiff provided no explanation for the difference in values from those claimed in the bankruptcy case, and the insurer denied the claim on the basis of the policy's fraud clause. Plaintiff sued the insurer for breach of the insurance contract, and the district court granted summary judgment in favor of the insurer.

Judge(s):

BOGGS, CLAY, and GILMAN, Circuit Judges

ABI Membership is required to access the full summary. Please Sign In using your ABI Member credentials. Not a Member yet? Join ABI now - it is absolutely worth it!