Carman v. Prudential Insurance Co. of America

MATTHEWS, Justice,

dissenting.

I agree that the statute of limitations does not begin to run prior to the expiration of the presumptive death period. This prevents insurance companies from taking the inconsistent position of refusing to hon- or a claim because the date of disappearance is not the date of death, but using the date of disappearance as the date of death to begin the statute of limitations. See American Nat’l Ins. Co. v. Hicks, 35 S.W. 2d 128, 132-33 (Tex.Comm.App.1931). I do not agree, however, that the statute of limitations automatically begins to run on the date that the presumptive death period expires. That date merely fixes the date of death of the insured.

Suffering an insured loss does not begin the statute of limitations. What is required is a loss, and a demand for performance which is refused. See Howarth v. First Nat’l Bank of Anchorage, 540 P.2d 486, 490-91 (Alaska 1975), aff'd, 551 P.2d 934 (Alaska 1976); Fireman’s Fund Ins. Co. v. Sand Lake Lounge, Inc., 514 P.2d 223, 227 (Alaska 1973). “Ordinarily, a cause of action accrues in favor of a beneficiary of a life insurance policy upon the happening of the death of the insured and notice to the company accompanied by a demand for payment.” Jalet, Mysterious Disappearance: The Presumption of Death and the Administration of the Estates of Missing Persons or Absentees, 54 Iowa L.Rev. 177, 195 (1968) (emphasis added).

What the majority opinion has done in this case is to eliminate the demand requirement in presumptive death cases. Under the majority’s rule, the statute of limitations automatically begins to run on the day that death is presumed. The statute runs without any demand.

Under the doctrine of presumed demand, “a demand will be presumed at the expiration of the reasonable period within which it should have been made, which is ordinarily the period of the statute of limitations.” Gossard v. Gossard, 149 F.2d 111, 112-13 (10th Cir.1945).

The maximum reasonable time for making the demand, which is a condition precedent to the cause of action, is generally held to be the number of years specified by the statute for bringing suit, and if no actual demand is made within the period of the statute of limitations, it will be presumed to have been made at the expiration of the statutory period, thus starting the running of the statutory time.

Barer v. Goldberg, 20 Wash.App. 472, 582 P.2d 868, 871 (1978); see also 51 Am.Jur.2d Limitation of Actions § 128, at 697-98 (1970); Annotation, When Statute of Limitations Begins to Run Against Action on a Contract Which Contemplates an Actual Demand, 159 A.L.R. 1021, 1025 (1945). If a late demand is made, the statute is nonetheless regarded as having commenced to run as of the time of the presumed demand. 51 Am.Jur.2d Limitation of Actions § 128, at 698 (1970).

I would adopt this approach. Thus, the rule of law which I believe should govern this case would provide that the statute of limitations begins to run on the date that the beneficiary's demand for payment is refused. If no demand is made within the six-year limitations period beginning at the date of presumed death, the demand would be presumed to have been made, and refused, at the expiration of that period. Such a proviso is necessary so that the *747beneficiary cannot indefinitely postpone the running of the statute of limitations.1

The rule which I would adopt is to be preferred to that which the majority has adopted for three reasons.

First, it is consistent with the rule which should be applied in insurance cases not involving presumed death as to the date when the statute of limitations should begin to run when no demand is made.

Second, it allows for and recognizes the efficacy of actual demands made within six years after the date of presumed death. As such, it is consistent with the actual demand rule of Fireman’s Fund and Ho-warth while the rule adopted by the majority is not.

Third, one may reasonably say that the majority’s rule is too short when measured by the general rule that the six-year period begins from the refusal of a demand, while the rule which I would accept is too long. The author of the Annotation, When Statute of Limitations Begins to Run Against Action on a Contract Which Contemplates an Actual Demand, 159 A.L.R. 1021, 1025 (1945) says just that: “Both rules dispense with actual demand. The one shrinks the contract; the other expands it; by both it is overthrown.” However, there seems to be no middle ground which commends itself. In such a case, the longer period is to be preferred. “Where two constructions as to the limitations period are possible, the courts prefer the one which gives the longer period in which to prosecute the action.” Safeco Ins. Co. v. Honeywell, Inc., 639 P.2d 996, 1001 (Alaska 1981).

Applying this doctrine of presumed demand to this case, Mrs. Carman would be presumed to have made a demand at the expiration of the six-year limitations period which began when death was presumed, August 7, 1975. Thus, the date of the presumed demand would be August 7, 1981. That demand would be deemed immediately refused and the statute of limitations would begin to run from August 7, 1981. Since the present action was brought on August 7,1985, it would not be barred.

. The rule which we have adopted in Howarth and Fireman’s Fund, that the statute of limitations does not begin to run until there has been a denial of the insured’s demand, requires some such terminating proviso for the same reason.