Boyd v. Liberty Life Ins. Co. & Selectquote Insurance Co.

Robert F. Goings

Case Conclusion Date:June 13, 2012

Practice Area:Litigation

Outcome:Summary Judgment Affirmed

Description:A prospective insured orally agreed to a life insurance premium rate during a discussion with an insurance broker. It was thereafter determined that the wrong premium rate had been quoted due to a clerical error and that in fact, the rate was much higher. The insured filed suit and the trial court granted summary judgment to the insurer and the broker. The South Carolina Court of Appeals affirmed the grant of summary judgment, finding that no valuable consideration existed between the insured and the insurer because the insured had not paid the premium under S.C. Code Ann. § 38-1-20(46) (Supp. 2011), such that no contract was formed.