Kathleen M. Downing v. Country Life Insurance Company, 473 P.3d 699

In Oct. 2015 Amy Downing purchased a whole life policy ($500,000) with a Paid‑Up Additions Rider (PUAR); annual PUAR premium ≈ $9,320 and an illustration showing a $1,095,741 rider amount.
Agent Sullivan explained the PUAR as an investment that maximized cash value; he testified he never told Amy the PUAR death benefit was a flat amount.
After one year Amy intended to abandon the policy; she assigned it to her mother Kathleen, who reviewed and signed an illustration and began paying premiums as an investment.
Amy died in Jan. 2017 (policy year 2). Country Life paid $500,000 under the base policy and $108,855 under the PUAR; Kathleen sued claiming $1,095,741 minus the amount paid.
The PUAR text defined paid‑up life insurance by a formula (net premium, mortality table, interest) and included a table of guaranteed values on page two showing increasing paid‑up insurance and cash values over time.
The superior court granted summary judgment to Country Life, finding the PUAR reasonably read as a variable/increasing benefit and not a flat second‑year payout; the Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the PUAR provided a flat death benefit of $1,095,741 in policy year 2	First page of "Policy Specifications" plainly lists $1,095,741 as the rider amount; insured reasonably expected that amount	PUAR language, the page‑two guaranteed values chart, illustrations, and definitions show the rider amount varies with time and premiums	Court held the PUAR is reasonably read as a variable, time‑dependent benefit; no flat $1,095,741 in year 2; SJ for insurer
Whether the first page alone controls or the policy must be read as a whole	The first page (followed by a blank page) signals the death benefit amount; insureds could reasonably stop there	Contract must be read in whole; table of contents and the immediately following chart on page two supply controlling specification and calculation	Court held terms must be read together; cannot ignore page two and illustrations; no ambiguity favoring insured
Whether the doctrine of reasonable expectations or ambiguity requires construing the policy for the insured	Insured claims ambiguity between first page and table of values; doctrine supports construing in insured's favor	No objectively reasonable expectation of a flat million‑dollar rider given the PUAR text, charts, illustrations, and agent's explanations	Court found no ambiguity reasonably supporting insured's expectation; doctrine does not salvage plaintiff's claim

U.S. Fire Ins. Co. v. Colver, 600 P.2d 1 (Alaska 1979) (articulates doctrine of reasonable expectations for insurance contracts)
Allstate Ins. Co. v. Teel, 100 P.3d 2 (Alaska 2004) (construe coverage broadly; exclusions narrowly)
State Farm Mut. Auto. Ins. Co. v. Dowdy, 192 P.3d 994 (Alaska 2008) (ambiguity exists only when contract is reasonably susceptible to differing interpretations)
C.P. ex rel. M.L. v. Allstate Ins. Co., 996 P.2d 1216 (Alaska 2000) (reasonable expectations doctrine explained)
Dugan v. Atlanta Cas. Cos., 113 P.3d 652 (Alaska 2005) (even sloppy drafting does not require twisting contract if reasonable interpretation favors insurer)
Hahn v. GEICO Choice Ins. Co., 420 P.3d 1160 (Alaska 2018) (addresses interpretation of insurance policy language)