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State Farm Fire and Casualty Company v. Riddell National Bank
984 N.E.2d 655
Ind. Ct. App.
2013
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Background

  • Riddell, as mortgagee, held a security interest in a Parke County home whose owners filed bankruptcy.
  • The homeowners executed a deed in lieu of foreclosure to Riddell after bankruptcy proceedings.
  • Riddell discovered significant property damage (water, mold, structural issues) in 2009 but the claim was not filed until 2011.
  • State Farm insured the property and the policy required filing suit within one year after the loss.
  • Indiana Code § 27-1-13-17 prohibits policy terms restricting actions to less than two years from loss.
  • Conformity-to-state-law clause in the policy directs applicability of state law where a policy term conflicts.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the policy creates a two-year limitations period Riddell contends the statute applies as a default two-year period. State Farm argues only a one-year term is enforceable, but the statute governs if in conflict. The ten-year default applies; the one-year term is void and claim timely.

Key Cases Cited

  • Jones v. Ind. Farmers Mut. Ins. Co., 926 N.E.2d 116 (Ind. Ct. App. 2010) (statutory interpretation principles; unambiguous statutes applied)
  • S.C. Nestel, Inc. v. Future Const., Inc., 836 N.E.2d 445 (Ind. Ct. App. 2005) (contract interpretation; extrinsic evidence when ambiguous)
  • Shorter v. Shorter, 851 N.E.2d 378 (Ind. Ct. App. 2006) (contract interpretation; plain meaning of terms)
  • Perryman v. Motorist Mut. Ins. Co., 846 N.E.2d 683 (Ind. Ct. App. 2006) (unambiguous policy provisions void insufficient limitation)
Read the full case

Case Details

Case Name: State Farm Fire and Casualty Company v. Riddell National Bank
Court Name: Indiana Court of Appeals
Date Published: Feb 20, 2013
Citation: 984 N.E.2d 655
Docket Number: 61A01-1204-PL-159
Court Abbreviation: Ind. Ct. App.