Untitled Texas Attorney General Opinion

.c-. THEA-JT~RNEY GENERAL Board of Insurance Opinion No. O-2749 Commissioners Re: Would it be permissible inaustin, Taxas for the Insurance Department to issue a permit under the Attention: Mr. J. J. Timmins burial association law and allow the association to furnish tomb- Gentlemen8 stones as merchandise? Your request for an opinion has been received and care- fully considered by this department. We quote from your request as follows: “I am enclosing letter received from . . . asking the procedure to be employed for securing a charter Srom the Board of Insurance Commissioners for a burial association and allow them to furnish merchandise con- sisting of a tombstone, in an amount not to exceed $1.50.00. “Please check Senate Bill 135, &cts of the Forty- Sixty Legislature, particular, Sections 23 and 24 thereof, and advise this Department if, in your opinion, it would be permissible for this Department to issue a permit under the burial association law and the asso- ciation to furnish tombstones as the merchandise.” Sections 23, 24, and 25 of Senate Bill 135, Hcts of the Forty-sixth Legislature of Texas, read as follows: “Sec. 23. Burial Association. Any individual, in- dividuals, firms, co-partnerships, corporations or asso- ciations doing the business of providing burial or fun- eral benefits, which under any circumstances may be pay- able partly or wholly in merchandise or services, not in excess of One Hundred and Fifty ($150.00) Dollars, or the value thereof, are hereby declared to be-burial companies, associations or societies, and shall organize under pro- visions of Chapter 2’74, Acts of the Forty-first Legisla- ture, 1929, and amendments thereto; and shall operate un- der and be governed by Chapter 274, ,acts of the Forty- first Legislature, 1929, and amendments thereto, -and this act, It shall be unlawful for any individual, indivld- uals, firms, co-partnerships, corporations, or associa- tions, other than those defined above, to engage in the Board of Insurance Commissioners, page 2 (O-2749) business of providing burial or funeral benefits, ~which under any circumstances may be paid wholly or partly in merchandise or services .I1 Vet. 24. Policies or certificates issued by bur- ial associations shall provide for payment of the benefit in certain stipulated merchandise and burial service, which shall be scheduled in the policy or c,ertificate and approved by the Board of Insurance Commissioners .as being of the reasonable value as stated in the face of. the pol- icy, unless the insured shall at the time said’policy is issued elect to have same paid in cash. The policy shall showy in writing the election made. If the association issuing said policy shall fail or refuse to furnish the merchandise and services provided for in the policy, same shall be paid in cash. II “Sec. 25. Rules and Regulations. The Board. is here- by authorized to promulgate reasonable rules and regula- t ions to carry out the purposes o,f this Acts.” 9 Corpus Juris, Page 1100, define,s the term “burial” as ,follows: “Burial. The act of .interring the dead.” Words and Phrases, Vol. 5, Permanent Edition, Page 961, defines the term llburialll as follows: !‘Word ‘burial1 means act of burying a de~ceased person, sepulture, interment, act of depositing~~a dead boty in the earth, in a tomb or vault,~ or in the water; the act of in- terrin the human dead. s . Brady v. Presnell, 169 S.E. 278, 2 0, 204 N.C. 659.” 27 Corpus Juris, ‘Page 929, defines the, term “funeral” as 1111;s :” “Funeral.. The disposition of human bodies after death, with the accompanying rites and ceremonies.* 1 Joyce on Insurance 7c defines burial insurance as “a contract based upon a legal consideration whereby’the obliger un- dertakes to furnish the obligee, or one of then latter’s near rela- tives,, at death, a burial reasonably worth a~ fixed -.sum.ll Also see the cases of Sisson, et al.; vs. Prata Undertaking Company, 141’ A. 76; State ex rel Fishback VS. Globe;Casket and Undertaking Company, 143 P.,,878; Renschler VS. State ~107 N.,E. 758. , Burial associat,ions are associations which provide for the burial of its members. See the case of, State ex rel Coleman Board of Insurance Commissioners, page 3 (O-2749) vs. Wichita Mutual Burial Association, 73 Kansas 179, 84 Pa- cific 7579 We quote from the case of State ex rel Fishback vs. Globes Casket and Unde’rtaking Company, 54 L.R.A.N.S. pages 977, 978, and 979 as follows: I, . . . These certificates are in two forms. In the one the corporation agrees, on the death of the holder, ( to take charge of the burial of said holder, and pro- vide the necessary furnishing and materials therefor to the value.of one hundreds ($100)~ dollars as follows: One black broadcloth; white or colored plush casket; one out- side box for. casket; one hearse two carriages; one burial robe; necessary embalming; necessary accessories; and services ~of funeral direct or. t The other is similar in form, with the exception that it does not name the value of the furnishings, and provides that the corporation will take charge of the funeral of the holder ‘on the sur- render of this receipt,’ 2nd will furnish the hearse and two carriages in places~only where they are obtainable. “That contracts of the nature of the contract here in question are ,insurance contracts, and subject to con- trol under the insurance statutes, is the general trend of ,authority. In State, ex rel. Coleman v. Wichita Mut. Burial iisso. 73 Kan. 179, 84 Pac. 757, the organization in question was one estensibly to secure to the members th,ereof a decent burial. The expenses were defrayed by assessments levied upon the members. Two classes of cer- tificates were issued,. one entitling members to a funeral worth $100, and the other a funeral worth $50, accordingl,y as they paid the greater or lesser assessment. It was organized by an undertaker, through whom alone burials could be had. The court held the association an insurance company and subject to the insurance laws of the state. Passing upon the question, the court said: ‘We conclude from the foregoing facts that the ‘business designed to be transacted under the’ plan of the ‘d\richita Mutual Burial Association ,is, plain,, ordinary insurance e Membership in this association insures ‘to each member above ten years of age that which is equivalent to $100 cash, payable at the death of such member to whomsoever would otherwise defray the ~burial expense,s of such decedent. If the cer- tificate of membership issued by this burial association be designated a “policy,” the assessment a “premium,” and those who are relieved from paying the funeral expenses of the deceased member “beneficitiries,lT this association, both in general plan and phraseology, would be a substan- ‘tial duplicate of the. ordinary mutual insurance company. Board of Insurance Commissioners, page 4 (O-2749) The fact that no beneficiary is specifically named de- serves little consideration, since in reality one exists, and may be ascertained with as much certainty as if di- rectly and specifically mentioned. Whoever would other- wise pay the burial expenses of the deceased member is, by being relieved of that burden, as directly benefited to the amount of such expenses as if the cash were paid immediately to such person. If the deceased member leave an estate, the whole thereof, undiminished by the burial expenses, which would otherwise be paid therefrom, will be received by his heirs. If he leave no estate, then his Immediate relatives and friends, who would otherwise have to furnish the expenses of his burial, will be bene- fited by being relieved of that burden.’ “To the same effect is the case of-State v. Wlllett, 171 Ind. 296, 23 L.R.4. (N.S.) 197, 86 N.E. 68, in which the court used the following language: ‘The contract was issued by an association whose declared object was to se- cure or make certain, by a system of mutual contribution, to each member of the association, at death, the specific benefit of $75 for application to his burial service. This was indemnity or security, that, at the cessation of the life of the member, a certain sum of money would be payable by the association for his burial, whether the deceased had paid one assessment or a thousand. The con- trolling elements of the contract, as interpreted by the by-laws, are in all material respects similar to those of an ordinary mutual life insurance company , . . It is simply a business enterprise in which the contract holder is promised a definite thing in consideration of his per- formance of a definite undertaking on his part. . . .I1 Section 24 of Senate Bill 135 of the Forty-sixth‘Legis- lature of Texas, supra, provides that llpolicies -or certificates issued by burial associations shall provide for payment of the benefit in certain stiaulated merchandise and burial service, which shall be Scheduled in he ~olicv or certificatg and aonroved bv the B o ar f r as being of the reasonable value as stated in the face of the policy, unless the insured shall at the time said policy is issued elect to have same paid in cash.” The statute also provides that the policy shall show the election made, and provides that if the burial association fails or refused to furnish the merchandise and serv- ices provided for in the policy that the association then must pay the benefits in cash. We have been informed by the Board of Insurance Commis- sioners that they have a proved many policies of burial insurance as outlined by Section 2 f: supra, providing for certain stipulated items of burial and funeril merchandise and services. The Board Board of Insurance Commissioners, page 5 (O-2749) furnished us with a copy of a certificate or policy of a burial association which contains benefits usually listed by burial associations and approved by the Board. Such stipulated merchan- dise and servi,ce are as follows: “BENEFITS .~, ~... “The funeral service and merchandise covered un- der this policy shall consist as follows: 1. Casket and substantial outside box, casket to be octagon end, oval top hinged cap, made of cy- press, wood, covered with crepe, lined with silk, trimmed with full length extension handles. 2. Care and Preparation of the remains. 3. Burial Garment, either suit or dress. 4. Door Badge Casket Veil, Pallbearers’ Bouton- n~iere s , Press Notice;, Use of Funeral Chapel if desired, or services conducted in home or church if preferred, and Memorial Record Book. 5. Cemetery and Funeral Equipment. The above does not include cemetery fees and expenses. 6. Transportation of flowers, metal grave markers, and floral acknowledgment cards. 7. Use of Hearse Service to any point within a ra- dius of seventy-five (75) miles of Austin, Texas, this service to include transferring remains from the home, hospital, or point of death to the Funeral Home; return to the home, to the Church or Chapel and to the cemetery.” The above listed items of burial merchandise and fun- eral services would provide a respectable burial for a deceased person. It is our opinion that a burial association which does not pay its benefits in cash must furnish such merchandise and services as would provide a respectable burial for its deceased member. We are also of the opinion that the various items of burial merchandise and funeral services are not separately a proper item of burial insurance, that is to say, we do not think an association which agreed to furnish a casket alone, or a shroud alone, or clothing for the deceased alone, or hearse serv- ice alone, or embalming service alone, for a regular premium, would be a burial association and should not be granted a char- ter or licemse as a burial association. Board of.Insurance Commissioners, page 6 (O-2749) Tombstones or monuments are erected at the grave of a deceased person for the purpose of marking his grave, and for the purpose of perpetuating the memory of said de- ceased person. Strictly speaking, the erection of a tombstone or monument is no part of a burial. However, our courts in Texas have frequently allowed as funeral expenses in the set- tlement of a decedent’s estate expenses for the erection of monuments and tombstones, dependent upon the condition of de- cedent’s estate. It is our opinion that the association you describe in your letter which pays its benefits in tombstones alone is not a burial association and should not be aranted a permit as such. Very truly yours ATTORNEYGENERALOF TEXAS . /s/ By Wm. J, Fanning Sm. J. Fanning, Assistant . APPROVEDOCT 16, 1940 Is/ Grover Sellers FIRST ASSISTANT ATTORNEYGENERAL APPROVED: OPiNIOE COMMITTEE BY: BWB, CHAIFLMAN ~. WJF:ew:wb