| ICSC Legal Database - Cases | Monday, February 22, 1999 05:01 PM |
| Citation: |
| Alabama Farm Bureau Mutual Insurance Company v. Meyers, 516 So. 2d 661 (Ala. Civ. App. 1987). |
| Issue: |
| Whether a vendor's insurance company was obligated to pay for damages which occurred to vendor's house |
| subsequent to the execution of a contract of sale yet prior to the closing of the transaction? in addition, if the |
| insurance company was obligated to pay, whether the vendor was then obligated to transfer the insurance |
| proceeds to the purchaser in order to reimburse the purchaser for monies expended on repairing the house? |
| Facts: |
| Plaintiff-vendor sold a house to the purchaser which was damaged during a hail storm sometime between the |
| time of the execution of the contract for sale and the closing of the transaction. The damage was discovered |
| sometime after closing and after the purchaser had paid the full purchase price for the house. The purchaser |
| paid $1,913.00 to repair the damage to the house and then sued both the Plaintiff and the Defendant-insurance |
| company for insurance proceeds for the damage to the house. Plaintiff filed a cross claim against Defendant. |
| The district court dismissed the purchaser's action against the Defendant-insurance company and upheld the |
| cross-claim against the Defendant-insurance company and the purchaser's damages claim against the |
| Plaintiff-vendor. Both the Plaintiff-vendor and the Defendant-insurance company appealed to the circuit court. |
| The circuit court affirmed the district court's ruling. The Plaintiff vendor and Defendant-insurance company |
| Holding: |
| Affirmed. The Court held that the Plaintiff had an insurable interest at the time of the hail storm; and therefore, |
| Defendant was obligated to pay insurance proceeds to Plaintiff. The court further held that a constructive trust |
| had been established for the benefit of the purchaser upon Plaintiff's realization of the insurance proceeds. |
| Plaintiff was then obligated to transfer these proceeds to the purchaser. |
| Classification 1: |
| Insurance |
| 00116 - Legal Update - Winter 1987 |
|