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Prudential Insurance Company Of America v. Moore, Administrator Of Salgue

• 1913 • 231 U.S. 560 • White Court
In the case of Prudential Insurance Company of America v. Moore, Administrator of Salgue in 1913, the U.S Supreme Court ruled on a dispute involving an insurance policy claim. The decedent had taken out two life insurance policies with Prudential and named his wife as beneficiary. After her death, he did not change the beneficiary designation before his own death. His administrator argued that since there was no living designated beneficiary at the time of his death, proceeds should go to his...Open Case
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Chief White Court
Term: 1913
Docket: 47
231 U.S. 560
34 S. Ct. 191
58 L. Ed. 367
1913 U.S. LEXIS 2518
Argued: Nov 06, 1913

Prudential Insurance Company Of America v. Moore, Administrator Of Salgue

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Opinion Summary
AI Abstract

In the case of Prudential Insurance Company of America v. Moore, Administrator of Salgue in 1913, the U.S Supreme Court ruled on a dispute involving an insurance policy claim. The decedent had taken out two life insurance policies with Prudential and named his wife as beneficiary. After her death, he did not change the beneficiary designation before his own death. His administrator argued that since there was no living designated beneficiary at the time of his death, proceeds should go to his estate under state law (New Jersey). However, Prudential claimed that according to their company's bylaws and terms within each policy contract - if a primary beneficiary predeceases or dies simultaneously with insured person without any contingent beneficiaries named then proceeds are payable to deceased's relatives in specific order: children first; if none exist then parents; if none alive then brothers/sisters etc., which excluded payment into deceased’s estate directly. The court sided with Prudence stating that these rules were binding upon all who took out policies from them because they formed part of every contract made by it for insurance unless expressly waived or modified by agreement between parties involved.

Dissent Summary
AI Abstract

In the dissenting opinion for Prudential Insurance Company of America v. Moore, it was argued that the insurance company should not be held liable for the death of Salgue due to suicide within two years after his policy was issued. The justice disagreed with the majority's interpretation of a clause in Salgue's life insurance contract which stated that if he died by suicide within two years, whether sane or insane at the time, no benefits would be paid out. He believed this clause should have been interpreted literally and strictly enforced as written in order to uphold contractual obligations and principles. This would mean denying payment to Salgue’s estate because he did commit suicide within those first two years following issuance of his policy regardless of mental state at time of death.

Opinion written by Justice JMcKenna
Decided: Dec 22, 1913
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