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