KMJ Services, Inc. v. Hood, 115 So. 3d 34

KMJ requested marine insurance via Ellsworth, with Tom Hood as KMJ's agent.
GCM acted as wholesale broker, binding pool and non-pool insurers for KMJ's two policies.
Policies GCM21662 (CGL) and GCM10581 (Marine Package) were issued with ICC as premium financier.
ICC's power of attorney allowed cancellation if KMJ defaulted on premium payments; ICC notified insured, Ellsworth, GCM, and listed insurers.
KMJ defaulted on the premium payments; cancellation notices were sent; GCM canceled the two policies.
KMJ sued for damages; trial court granted summary judgment in favor of ICC and others; appellate review focused on Louisiana law interpretation of 9:3550.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did notice to GCM suffice for all insurers under 9:3550?	KMJ argues notice to GCM only to listed insurers was ineffective.	GCM, as wholesale broker for all insurers, validly received notice on behalf of all insurers.	Yes; notice to GCM sufficed for all insurers.
Did GCM have authority to cancel coverages not listed on the Schedule?	GCM lacked authority to cancel coverages not listed on the Schedule of Financed Policies.	As wholesale broker for all insurers, GCM could receive cancellation notices for all coverages.	Yes; GCM had authority to cancel all coverages.

Flowers v. Wal-Mart Stores, Inc., 99 So.3d 696 (La.App. 5 Cir. 2012) (summary judgment de novo standard; no live testimony)
Robinson v. Jefferson Parish Sch. Bd., 9 So.3d 1035 (La.App. 5 Cir. 2009) (procedural posture and summary judgment standards)
Hodges v. Colonial Lloyd’s Ins., 546 So.2d 898 (La.App. 1 Cir. 1989) (strict compliance requirements for 9:3550 cancellation)
Stephens v. LeBlanc, 879 So.2d 262 (La.App. 1 Cir. 2004) (power of attorney under 9:3550(G) authorization)
Hunter v. Automotive Cas. Ins. Co., 606 So.2d 571 (La.App. 5 Cir. 1992) (POA authority to cancel under 9:3550(G))
McManus v. S. United Fire Ins., 801 So.2d 392 (La.App. 3 Cir. 2001) (agency determination in insurance transactions)