Insurance for reality tv shows

I admit it. I'm a fan of reality tv. Not only that, I don't understand the disdain people hold for that genre. I don't see a bright line between "scripted" and "unscripted" shows. Plenty of so-called scripted shows feature ad libs or at least input by actors. Reality shows are plotted, just by people whose job title is producer rather than writer. I liken the process to eliciting testimony at trial. You can prep your witnesses, you can ask the right questions, but sometimes it's the unexpected answer that leads to magic (or the money shot).

Here's a great article by Emily Holbrook at Risk Management Monitor on insurance issues for reality tv. Best quote:



What types of reality shows spur the most insurance claims?

LM: Many times it’s more of the “walk and talk” shows as opposed to
those with stunts that spur the most claims. Audience members are often hurt
while being moved in and out of the auditorium.



I'm waiting for the lawsuit by the estate and family of Russell Armstrong from Real Housewives of Beverly Hills.


On a related note, here's an article on how game shows insure large prizes.

Michigan Health Plan Tax Lawsuit Tests Business Community Priorities

A lawsuit filed last week in Federal Court seeking a declaration that Michigan’s Health Insurance Claims Assessment Act is preempted by the Employee Retirement Income Security Act (ERISA) will certainly test existing legal precedent, but perhaps the more interesting test will be how the business community responds.

This blog previously reported that officials from one prominent business organization in the state had no intention of pushing back against the legislation at the time citing both internal and external political concerns. That said, they suggested that there would likely be “private” support of a legal challenge from within their organization if in fact the law was challenged.

It will be interesting to see how this “leading from behind” approach plays out. In a conversation with my source shortly before the lawsuit was filed, it was noted that Michigan self-insured employers are now starting to pay more attention to the law and what it means to them.

More specifically, this blog has learned that one prominent multi-state self-insured employer based in Michigan calculated its yearly projected expenses to comply with new law to be more than $250,000. Of course, the administrative headaches are just a bonus.

But even with such a direct adverse impact on their company, senior company executives remain guarded about expressing opposition to the new law.

Now that the legal flaws of new law have been laid bare in the detailed complaint filed against the state and word is starting to get out about its practical impact, we’ll see if any heads pop up out of the foxholes.

And while the this legal challenge is important to self-insured employers in Michigan and to other entities that pay healthclaims for Michigan residents for services received within the state, its significance extends more broadly.

Michigan is not the only state that is strapped for cash and looking for new revenue streams. If its new health plan tax law goes unchallenged, this will likely embolden other states to consider this same approach and the cornerstone of ERISA preemption will be greatly compromised, and with it, the viability of self-insured health plans.

I suspect that if Michigan self-insured employers in large numbers estimated the financial impact to their balance sheets if they were forced to switch to fully-insured health plans and publicly communicated this to policy-makers and business association leaders early on this train would have been pulled off the track before arriving at the courthouse door.

The state has declined to comment on the lawsuit thus far but is required to file a formal legal response in the next 30 days so it will soon become clear how they intend to fight this challenge.

Perhaps the business community may yet demonstrate some clarity with regard to where it stands.

A Tale of Two Domiciles...Revisted

We suggested a narrative earlier this year that two southern captive insurance domiciles would be worth watching to compare and contrast based on insurance commissioner appointments in each state. Let’s review.

The captive industry in South Carolina fell on hard times during the regime of Insurance Commissioner Scott Richardson who left office at the end of 2010. When newly-elected Governor Nikki Haley named David Black as his replacement in February, this blog reflected the puzzlement expressed by many industry and political insiders.

Mr. Black was a largely unknown quantity aside from being the CEO of an inconsequential life insurance company.

But the sparse resume and lack of ART industry credentials didn’t deter Governor Haley from appointing Mr. Black and pronouncing him as a savior. Consider her comments when naming him to the position where she said “Understanding the importance of your industry, I chose David Black to lead the Department of Insurance. He has the energy and capability to revitalize the captive industry for our state.”

As it turned out, he had neither

Earlier this week, Mr. Black abruptly announced his resignation to his staff via e-mail giving no specific reason for his decision.

So now Governor Haley has a chance for a second bite of the apple to get it right. This means naming someone to the position who is willing and capable to shake up the bureaucracy within the department and establish a firewall between the regulation of traditional insurance companies and alternative risk transfer programs, as originally envisioned by former commissioner Ernie Csiszar more than a decade ago.

A tall order for sure and we’ll be watching.

A very different story continues to play out in nearby Tennessee where Governor Bill Haslam tapped Julie Mix McPeak to head up the insurance department in that state.

This blog noted that Ms. McPeak had both the credentials and reputation to turn heads within the ART marketplace when word of her appointment surfaced. But her future success was not assured.

The first order of business as it related to the ART industry was to shepherd a bill through the Legislature that made comprehensive updates to the state’s captive statute. This effort proved more difficult than expected but Ms. McPeak was up to the task and that legislation, which she helped draft, was signed into law.

Since that development, she has been working methodically to assemble a top notch regulatory team and now most of the key positions have been filled and she introduced these individuals at an industry event earlier this month.

So armed with a progressive captive stature and a regulatory team inspired to transform Tennessee into a premiere captive insurance domicile, the stage has now been set for her to make it happen.

But let’s not get ahead of ourselves as there are certain to be pitfalls ahead as the domicile finds its footing under Ms. McPeak’s leadership in 2012. That said, the fact that leadership is on display is certainly refreshing for those vested in the growth of the ART marketplace.

This tale of two domiciles will continue.

Lynnwood auto repair shop charged with insurance fraud

A Snohomish County auto repair shop has been charged with insurance fraud after charging for repairs it didn't do and parts that it never installed.

Northwestern Collision, of Lynnwood, was charged Dec. 14 in Snohomish County Superior Court. Arraignment is set for Jan. 9.

In 2009, Farmers Insurance investigators inspected 11 vehicles that had been repaired by the shop between 2007 and 2009. Of the 11, 10 "had substantial and specific" deviations from the repair estimates that Farmers had agreed to.

Among the problems: parts missing and not replaced, repairs not performed, and repairing items that were supposed to be replaced.

On Dec. 8, 2010, officers from the state insurance commissioner's Special Investigations Unit, the State Patrol and the Snohomish County Sheriff's Office served a warrant at the company's Lynnwood office. They gathered up paper files on 10 of the 11 vehicles.

The records indicated that in some cases, new parts that were supposed to be installed were instead returned to the parts dealer.

The insurer was overcharged nearly $11,000, and had to buy one customer's car, which had been rendered unsafe to drive, for another $15,446.

Fourth Cir. Denies Coverage Based on Insurance and Related Work Exclusion

Post by Pete Dworjanyn
The Fourth Circuit Court of Appeals recently affirmed a South Carolina District Court judge’s grant of summary judgment to an insurer based on an endorsement excluding coverage for any obligation assumed in connection with an insurance contract or treaty, or any failure to carry out any contractual or other duty in connection with an insurance contract or treaty.  Houston Casualty Company v. St. Paul Fire & Marine Insurance Company, unpublished, No. 10-1835, Dec 6, 2011.

In 2003, Manuel Salazar was badly injured while working on a dam project in South Carolina.  He sued, among others, South Carolina Electric & Gas (SCE&G) the owner of the power lines that caused his injuries and McGriff, the insurance broker for the project. Salazar alleged that in addition to providing insurance brokerage services for the project, McGriff was responsible for performing safety inspections at the site and negligently failed to perform those inspections.  Houston Casualty, McGriff’s professional liability carrier, participated in the settlement of the suit.  St. Paul, McGriff’s CGL and excess insurer, denied coverage. The present insurance coverage litigation was an attempt by Houston Casualty to seek contribution from St. Paul.

McGriff had procured an Owner-Controlled Insurance Program (OCIP) and, as part of the program, had provided a Manual of Insurance Procedures to SCE&G and all contractors.  The OCIP Manual provided that the Owner’s Safety Representative, in conjunction with the general contractor and McGriff, would furnish safety posters, loss and inspection reports and provide overall supervision of the project’s safety effort.  The manual also provided that a safety program had been established by the general contractor to conform with relevant standards and would be supervised and reviewed by the Owner’s Safety Representative and McGriff. 

The St. Paul policies contained an endorsement which provided, in part;

Insurance and related work. We won’t cover injury or damage or medical expenses for which the protected person may be held liable because of:
·         any obligation assumed by any protected person in connection with an insurance contract or treaty; or
·         any failure to carry out, or improper carrying out of, any contractual or other duty or obligation in connection with an insurance contract or treaty.

Houston argued that the exclusion did not apply because McGriff’s duty to inspect arose independently of an insurance contract and, alternatively, there were disputed issues of material fact. 

Affirming the District Court, the Court of Appeals held the plain language of the endorsement excluded coverage.  The exclusion specifically provided that it excluded coverage for claims arising out of “...other duty or obligation in connection with an insurance contract”.  Thus, Salazar’s claims would be excluded if they concerned an obligation that arose “in connection with” an insurance contract even though the contracted issued was not itself an insurance contract. The court held the OCIP Manual provided further support for its decision as claims based on those obligations undoubtedly arose “in connection” with an insurance contract, regardless of whether the manual itself was part of an insurance contract.            

Going green?

Going “Green?”

If you want to drive a car driven mostly by batteries, that is fine with me. But please don’t act snooty about it when I pass you in my twenty foot long four wheel drive Suburban. Have you noticed that some in the so-called “green movement” have an attitude?

Unfortunately, many green activists do not understand science. Building a Toyota Prius causes more environmental damage than a huge Hummer according to Chris Demorro in a March 7, 2007, article in The Recorder-Central Connecticut State University.

The Prius is partly driven by a battery, which contains nickel. The nickel is mined and smelted at a plant in Sudbury, Ontario. This plant has caused so much environmental damage to the surrounding environment that NASA has used the ‘dead zone’ around the plant to test moon rovers.

The plant is the source of all the nickel found in a Prius’ battery and Toyota purchases 1,000 tons annually. Dubbed the Superstack, the plague-factory has spread sulfur dioxide across northern Ontario, becoming every environmentalist’s nightmare. The nickel produced by this disastrous plant is then shipped via massive container ship to the largest nickel refinery in Europe.

From there, the nickel hops over to China to produce ‘nickel foam.’ From there, it goes to Japan. Finally, the completed batteries are shipped to the United States, finalizing the around-the-world trip required to produce a single Prius battery.

When you pool together all the combined energy it takes to drive and build a Toyota Prius, the flagship car of energy fanatics, it takes almost 50 percent more energy than a massive Hummer - the Prius’s now-defunct arch nemesis.

Through a study by CNW Marketing called “Dust to Dust,” the total combined energy is taken from all the electrical, fuel, transportation, materials (metal, plastic, etc) and hundreds of other factors over the expected lifetime of a vehicle. The Prius costs an average of $3.25 per mile driven over a lifetime of 100,000 miles - the expected lifespan of the Hybrid.

The Hummer, on the other hand, costs a more fiscal $1.95 per mile to put on the road over an expected lifetime of 300,000 miles. That means the Hummer will last three times longer than a Prius and use less combined energy doing it.

So, if you are really an environmentalist - ditch the Prius. Instead, buy one of the most economical cars available - a Toyota Scion xB. The Scion only costs a paltry $0.48 per mile to put on the road. If you are still obsessed over gas mileage - buy a Chevy Aveo and fix that lead foot.

One last fun fact for you: it takes five years to offset the premium price of a Prius. Meaning, you have to wait 60 months to save any money over a non-hybrid car because of lower gas expenses.

If environmentalists were serious and truly considered the facts, they might ditch all the new green technology and just go back about a few years.

Back then, no one used an engine that burnt gas just to cut the grass, when a mower one pushed yourself silently trimmed it. Walking and working gave folks so much exercise, that no one joined a health club to run on treadmills operated by electricity. Back then, people returned milk bottles and beer bottles that were sterilized and refilled. Folks took the stairs rather than an elevator, and always walked everywhere. Clothes hung on the line were dried by everyday solar and wind energy at work; instead of an energy -wasting machine burning electricity. In the kitchen, all was stirred by hand because there were no electric machines to do everything.

Back then, kids rode their bikes to school, or walked instead of turning their moms into a 24-hour taxi service. Thirsty folks did not chunk a plastic bottle every time they had a drink of water. Writing pens, cloth diapers, lighters and razors were refilled, instead of throwing away the whole thing.

Being Green is not bad, but you are probably doing it wrong.

When Mr. Peel is not single-handedly melting the ice caps in a four wheel drive, he pursues better results for his injured clients. Mr. Peel often addresses churches and clubs and can be contacted through www.PeelLawFirm.com, wherein other articles can also be found.

Cease and desist order issued to TracGuard Services

The Washington state insurance commissioner's office has told a Florida-based vehicle service contract provider to stop selling unauthorized contracts in Washington state.

TracGuard Services LLC, Jose L. Terry and Alberto Tudela, all of North Miami, have been ordered "to immediately cease and desist from engaging in or transacting the unauthorized business of insurance" in Washington.

Neither the company nor the two men are authorized to solicit or transact insurance in the state. They have not registered as a motor vechicle service contract provider in Washington.

The three have been ordered to notify all Washington residents who have purchased a service contract from them. It also warns that, pursuant to Washington state law, unauthorized insurers "shall remain personally liable for performance of the contract."

Cease and desist order issued to Mill Creek man

A Mill Creek man and company have been ordered to stop selling unauthorized vehicle service contracts.

The order names Scott L. Stevens and RVProtection.net, Inc., both of Mill Creek, Wash. In August of 2010, they sold a consumer a vehicle service contract offered by Genuine Warranty Solutions, Inc.

The problem: Genuine Warranty Solutions, Inc. is not a registered vehicle service contract provider in Washington.

The Dec. 19 order took effect immediately. Stevens and the company have the right to appeal the order.

Happy New Years, Everyone.

I wanted to post some funny insurance jokes today, but after wasting a lot of time searching the web I couldn't find any that were actually funny. So I asked my ten year old daughter for the best joke she knows. This is what she said:

An alien comes down from Mars. He changes into the form of a human except he doesn't give himself any ears because he thinks they look weird.

He starts a business and puts a "Now Hiring" sign on the window. The first person comes in to ask for a job. The alien asks, "Do you notice anything odd about me?" The person says, "Yes, you don't have any ears." The alien disintegrates him on the spot.

The second person comes in to ask for a job. The alien asks, "Do you notice anything odd about me?" The person says, "Yes, you don't have any ears." The alien disintegrates her.

The third person comes in to ask for a job. The alien asks, "Do you notice anything odd about me?" The person says, "Yes, you're wearing contacts."

The alien says, "How did you know that?"

The person answers, "You can't wear glasses if you don't have any ears."

Happy Holidays

Happy holidays from the Ontario Insurance Law Blog! Thanks for your support and we hope you continue to enjoy the blog in the new year. See you in 2012!

Public notices and hearings: Change of incorporation, proposed acquisition, etc.

Notices and upcoming hearings from our public notices web page:

Proposed acquisition: Humana is proposing to become the sole owner of Arcadian Management Services and its affiliates. We've completed our review of the application for acquisition of control. No hearing's been scheduled yet, but will be soon.

Incorporation change: The Safeco Companies have requested approval to have New Hampshire be their state of incorporation. The companies, which were acquired by Boston-based Liberty Mutual in 2008, say the change would not affect any Washington policyholders, and that there would be no interruption in coverage. A hearing is scheduled for Jan. 10, 2012 at 10 a.m. in our Tumwater office, which is at 5000 Capitol Blvd. Annual reports and other documents re: the request are posted here.

Change in port of entry/redomestication: Industrial Alliance Pacific Insurance and Financial Services have filed documents to change their port of entry/redomestication to Texas. A hearing is scheduled for Feb. 1, 2012 at 1 p.m. at our Tumwater office, which is at 5000 Capitol Blvd. Documents re: the request are posted here.

Judge issues insurance fraud ruling...in the form of a poem

And now for something completely different:

A Pennsylvania judge has issued a ruling in an insurance fraud case. What's unusual is that the judge issued his ruling in the form of a poem. From the Associated Press:
Justice J. Michael Eakin, writing for a 4-2 majority, concluded in six-line stanzas that a man's attempt to deposit a forged check appearing to be from State Farm didn't constitute insurance fraud.
"Sentenced on the other crimes, he surely won't go free, but we find he can't be guilty of this final felony," Eakin wrote. "Convictions for the forgery and theft are approbated — the sentence for insurance fraud, however, is vacated. The case must be remanded for resentencing, we find, so the trial judge may impose the result he originally had in mind."
A 3-page dissent by another judge, AP writer Marc Levy noted, did not rhyme.

GEICO fined $100,000 for overcharging customers in WA; company will also refund $7.5 million

A Maryland-based insurance company has been fined $100,000 after overcharging thousands of its Washington state customers.
The insurer, GEICO, is also refunding $7.5 million – plus 8 percent interest -- to the 25,267 affected auto insurance consumers by the end of the year.

“A computer database error caused the problem, which the company reported to us promptly,” said Washington State Insurance Commissioner Mike Kreidler. “GEICO has also agreed to a two-year compliance plan that includes multiple audits.”

An additional $50,000 fine was suspended, on the condition that the company abides by the terms of the compliance plan.

The refunds, many of which have already been paid, will average roughly $300. The company has been contacting active and former customers affected by the issue and expects to have all refunds paid by the end of the year.

On May 26, 2011, GEICO representatives self-reported the computer error, which resulted in 7 percent of the company’s Washington customers being overcharged for insurance between Aug. 24, 2009 and June 2011.

Fines collected by the insurance commissioner’s office do not go to the agency. The money is deposited in the state’s general fund to pay for other state services.

The complete order is posted at: http://www.insurance.wa.gov/oicfiles/orders/2011orders/11-0273.pdf.

Summary Judgment - Oral Evidence

In this post, we continue our discussion of the Court of Appeal's decision in Combined Air Mechanical Services Inc. v. Flesch, 2011 ONCA 764.

Rule 20.04(2.2) permits a judge to hear oral evidence on a summary judgment motion. The Court provided guidance on when this discretion may be exercised.

The Court held that a party that moves for summary judgment must be in a position to present a case capable of being decided on a paper record. The motions judge can decide if he or she requires viva voce evidence under r. 20.04(2.2). The purpose of the rule is not to allow a party to enhance the record it has put before the court.

An order for oral evidence will generally be appropriate where the judge concludes the exercise of powers under r. 20.04(2.1) will be facilitated by hearing oral evidence of a limited number of witnesses on one or more specific, discrete and likely determinative issues.

An order under r. 20.04(2.2) may be appropriate where:

(1) Oral evidence can be obtained from a small number of witnesses and gathered in a manageable period of time;
(2) Any issue to be dealt with by presenting oral evidence is likely to have a
significant impact on whether the summary judgment motion is granted; and
(3) Any such issue is narrow and discrete – i.e., the issue can be separately decided and is not enmeshed with other issues on the motion.

- Tara Pollitt

Appeals court holds judge not required to give jury instruction on presumption of consent to use vehicle if contrary evidence has been offered

McConnico, an employee of Dollar Rent-A-Car, struck and killed Kohlmeyer, a pedestrian, while he was driving one of Dollar's automobiles.

McConnico's primary responsibility was to deliver automobiles to hotels. On the evening before the accident McConnico took a Dollar vehicle to run a a personal errand. The accident occurred as he was driving the car back to Dollar the next day.

McConnico had signed a written acknowledgement when he was hired that he was prohibited from using company rental vehicles except under the direction of a Dollar manager, and that unauthorized use of a vehicle was grounds for discharge. He was in fact fired on the morning of the accident for violating the policy.

There was evidence that personal use of Dollar automobiles was commonplace and few employees were reprimanded for doing so.

Dollar and its excess carrier filed a declaratory judgment action seeking a declaration that there was no coverage because McConnico did not have express or implied permission to drive the car.
The excess policy provided coverage for liability incurred by Dollar and "anyone . . . using with [Dollar's] permission" an automobile Dollar owned.

After trial the jury returned a verdict that McConnico was an unauthorized driver, thereby finding no coverage.

On appeal, Kohlmeyer's estate argued that under Mass. Gen. Laws ch. 231, § 85C*, McConnico was presumed to be driving with Dollar's express or implied consent. The statute states that in certain circumstances in cases against automobile insurers a driver is presumed to have consent to drive a car.

In United Nat'l Ins. Co. v. Kohlmeyer, 81 Mass. App. Ct. 32 (2011), the Massachusetts Appeals Court held:



The presumption embodied in G. L. c. 231, § 85C is part of a legislative structure
supporting the Commonwealth's compulsory motor vehicle insurance requirements.
Read in the context of the statutes to which
§ 85C refers, the support structure operates in this fashion. An insurer's liability under an automobile policy “insuring against liability for loss or damage on account of bodily injury or death” becomes absolute when a covered loss occurs and is not conditioned on an insured's payment of the loss to the injured party. See G.L. c. 175 § 112, amended by St.1977, c. 437. If the injured party obtains a judgment against the insured, the injured party is entitled to bring an action against the insurer to reach and apply the insurance proceeds.
See G.L. c. 175 § 113; G.L. c. 214 § 3(9)
. In an action to reach and apply, the
presumption desired by the estate applies but, as § 85C
expressly states, only if the plaintiff is seeking to “reach and apply the proceeds of [a] motor vehicle liability policy, as defined in” G.L. c. 90 § 34A.


The court noted that the statute applied only to compulsory policies, and the policy at issue was excess, not compulsory.

It went on to hold that even if the statute had applied, the presumption would have been enough to meet the estate's burden initially, but it was rebuttable, "and continue[d] only until evidence [was] introduced which would warrant a finding contrary to the presumed fact." Because there was such evidence, the judge was not required to instruct the jury on the presumption.

*This link is to the statutes posted by the Commonwealth of Massachusetts. Massachusetts Lawyers Weekly recently ran an article explaining that this website is not updated frequently, and recent revisions to statutes are not shown.

Social media, liability and insurance

Social media and insurance? Hard to imagine those words together, but the new report by the Insurance Information Institute is pretty interesting reading.

Most of us rely on social media more and more these days - whether for work or to keep with friends and family. But we probably never think about the insurance impact (ie. liability issues).

Find out if you or your business could be at risk - here's the report.

Gap insurance

Here's an interesting article at The Frugal Toad on a type of insurance I'd never heard of. I was hoping that Gap Insurance might cover the jeans my kid spilled tomato sauce on just after I bought them. But it actually covers the difference between the actual value of a new car and what you paid for it, since new cars lose their value the instant you drive them off the lot.

Another solution to this problem: Don't buy new cars.

U.S. District Court holds that insurer who wrongfully denied duty to defend must indemnify insured where question of duty to indemnify is in equipoise

A couple of days ago I wrote about Manganella v. Evanston Ins. Co., 2011 WL 5118898 (D. Mass.), in which Evanston Insurance Company denied coverage for a sexual harassment claim because the misconduct began before the policy period.

At issue was the MCAD claim of Burgess against her employer, Jasmine Company, alleging that she had been harassed by Luciano Manganella since she began her employment a couple of years before the Evanston policy went into effect. At a deposition she clarified that although Manganella had made inappropriate comments prior to the policy period, she had not felt physically or emotionally threatened by him until after the policy period began.

Evanston made an argument that I don't quite understand that it was entitled to rely on readily knowable facts outside the complaint to deny coverage. (I don't understand it because the black letter law it cites states that facts outside the complaint may be used to trigger the duty to defend, not the opposite; and because the facts outside the complaint appear to trigger coverage rather than show no coverage.)

The court rejected Evanston's argument. It went on to hold that because it had breached its duty to defend Jasmine, Evanston is liable for the costs of settlement reached with Burgess. Although a breach of the duty to defend does not provide an automatic right to indemnity, an insurer that has wrongfully declined to defend a claim has the burden of proving that the claim was not within the coverage of the policy. "Because the evidence on this later issue is in equipoise, Evanston has not met its burden of showing coverage did not attach."

Court of Appeal comments on the new summary judgment rule

The Court of Appeal has now released its decision regarding the new summary judgment rule. The appeal was heard before a five panel Court and pertained to five action. It is released under the name Combined Air Mechanical Services Inc. v. Flesch, 2011 ONCA 764.

The Court held that there are three types of cases that are amenable to summary judgment:

1. Where the parties agree it is appropriate to determine an action by way of summary judgment (para. 41);
2. Claims or defences that are shown to have no merit (para. 42); and
3. Where the trial process is not required in the interest of justice (para. 44).

It is not necessary for the judge to categorize the type of of case in question. In fact, the Court held that the latter two types of cases are not to be viewed as discrete compartments.

The test for summary judgment is the "full appreciation test". The motions judge must ask "can the full appreciation of the evidence and issues that is required to make dispositive findings be
achieved by way of summary judgment, or can this full appreciation only be achieved by
way of a trial?" (para. 50). In cases that call for multiple findings of facts emanating from a number of witnesses and found in a voluminous record, summary judgment is not a substitute for the trial process. On the other hand, the full appreciation test may be met in document-driven cases with limited testimonial evidence, cases with limited contentious factual issues or where the record can be supplemented to the requisite degree at the motion judge's direction by hearing oral evidence on discrete issues.

It remains to be seen how this will impact summary judgment motions going forward. Are judges going to be more reluctant to grant summary judgment?

- Tara Pollitt

Judging GOD


JUDGING GOD

“Do not judge, or you too will be judged. For in the same way you judge others, you will be judged, and with the measure you use, it will be measured to you.”
Matthew 7:1-2 (NIV)

Even those unfamiliar with the Bible have likely heard some version of this verse quoted.
Often, this Scripture is used as a sword against a condemning critic.
For instance, if a Christian is claiming that Jesus is the only way to Heaven, a skeptic might say, “So you are saying all Hindus go to Hell…that’s judging and your Bible says you can’t judge!”
It actually says, if you judge, that measure will be used in judging you. Since Jesus Himself claimed to be the only way to Heaven, and then commanded followers to go tell that to the whole world, it seems highly unlikely that the skeptic’s point was valid. To be clear, Christians can be harsher than necessary. But in the end, there is Absolute Truth, and by definition, all short of that is, of course, false.
But the skeptic might allege that there is no such thing as Absolute Truth. Oddly, he would be asserting that, “the lack of Absolute Truth is absolutely true!” (Often, this irony is lost on skeptics.)

That being said, we are likely all guilty of judging others. Further, and more disturbingly, we all probably have judged God Himself.
Steve Jobs, the late founder of Apple Computers, was a skeptic. In his self-titled biography, Walter Isaacson describes a pivotal moment in Jobs’ life. At 13, young Steve Jobs was disturbed by a photo of starving children in Africa and confronted his pastor with it. He asked the minister if God knew about these children. The Pastor tried to explain that He did. Jobs reportedly proclaimed that he wanted nothing to do with worshiping such a God, and he never again darkened a church door.

That is judging God. And, I imagine, am just as guilty of it at times. Using human reasoning, Steve Jobs had a valid point. It brings us to one of the most important questions there is:

If God is all-powerful, and He does not just stop all the suffering, can He really be all loving? If He is all loving, but just cannot stop it, can He really be all-powerful?

It is this paradox that trips up most folks. And, we sit in our lawn chairs, as it were, and judge God Almighty—this as He reigns on the massive, golden throne of all the universe.
The harsh truth is, most of us feel we could run the planet, or at least our little lives, better than God. Don’t believe me? What is your reaction when you pray for something and it does not happen?

In fact, there is an all loving, all-powerful God that exists. And it is not you. And it is not me.
The wondrous question is not about the qualities of God, and whether He cares. It is why does He care at all? He made us, and we rebelled. In a perfect environment, we could not even follow one simple rule for long. That choice brought all the sin, suffering and death that we see. The amazing thing is that He sent a ransom for us—His Only Son—that we would not be lost forever.

The deepest tragedy then, is not even the awful deaths of starving children in Africa.

The worst thing is that people are so deceived that they choose a lifetime of godless skepticism to be followed by a godless eternity of torment.





Number of uninsured in WA hits 1 million

We posted a report this morning detailing our estimates of the number of Washingtonians with no health insurance, the amount of uncompensated care, and how those numbers are trending.

The upshot: We calculate that:
  • The number of uninsured has reached 1 million, or 14.5 percent of the state's population.
  • Uncompensated care (bad debt and charity care at hospitals, clinics, etc.) is nearly $1 billion.
  • And that both numbers are likely to continue to rise until 2014, when the major provisions of federal health care reform are slated to take effect.
  • The percentage of residents without health coverage worsened in 31 of 39 counties.
  • In several counties, more than 1 in 5 residents has no health coverage.
“This is a grim milestone for the state, and we believe the situation will remain bleak for two more years,” said Kreidler. “But it’s important for people to know that there is hope is on the horizon.”

Counties with a particularly high percentage of uninsured residents include: Adams, Grant, Okanogan, Franklin and Yakima. But the problem also worsened in King, Pierce, Snohomish and Spokane counties.

The good news: Assuming that federal health care reform takes effect as planned, more than 800,000 uninsured Washingtonians will be eligible in 2014 for expanded Medicaid eligibility or subsidies to help low- and middle-income families pay for health coverage.

This is the third report on the uninsured our office has put out since 2006.

U.S. District Court holds that continuing violation doctrine does not apply to insurance coverage disputes

Luciano Mangenalla owned and, after selling the company in 2005 to Lerner, managed a women's clothing boutique called Jasmine.



In 1998 Jasmine was sued by Sonia Bawa, a former employee, for sexual harassment. In the wake of the lawsuit Manganella caused Jasmine to purchase an Employment Practices Liability Insurance (EPLI) policy from Evanston Insurance Company. The insurance application stated that, except for the Bawa matter, Jasmine was unaware of any outstanding instances, real or alleged, of claims of wrongful employment practices including sexual harassment. Burgess, Jasmine's human resources manager, warranted that the statement was true.

In or after 2005 Manganella was terminated for sexually harassing four Jasmine employees, including Burgess.


In 2007 Burgess filed a complaint against Manganella, Jasmine, and Lerner at the Massachusetts Commission Against Discrimination. She alleged that since she began her employment in 1997, Manganella subjected her to nearly constant physical and verbal sexual harassment, and on five occasions intimidated her into engaging in sexual acts with him.


Evanston denied coverage because the "wrongful Employment Practice" had not occurred entirely during the coverage period.

At a subsequent deposition Burgess testified that she had not felt physically or emotionally threatened by Manganella before the fall of 1999, although he had made inappropriate comments before then.


Evanston argued that the continuing violation doctrine made Manganella's acts before the policy period part of a continuing pattern of harassment, so that even if Burgess did not feel threatened prior to the policy period the harassment began prior to the policy period, precluding coverage.


In Manganella v. Evanston Ins. Co., 2011 WL 5118898 (D. Mass. 2011), the court rejected the argument, noting that the continuing violation doctrine is intended to ameliorate the potentially draconian effects of the relatively short statute of limitations that governs discrimination claims. The court held that the doctrine should not be applied to shrink relief available to an insured.

Mad at God? Read this

MAD AT GOD?

If you have ever been mad at God, you are in good company. Most honest believers will admit that God has seemed--at times--distant, uncaring, unhearing, unjust or simply slow to react.

Given our human nature, it is understandable that these perceived shortcomings of the Divine One might outshine the things we are thankful to Him for.

We all know of Mark Twain. Born Samuel Clemens, he is the well-known author/creator of Tom Sawyer and Huck Finn. What is not as well known about this famous humorist is how he felt that the Almighty had utterly failed him. After he buried his son, two daughters and his beloved wife, he wrote the following:

“...a God who could make good children as easily a bad, yet preferred to make bad ones; who could have made every one of them happy, yet never made a single happy one; who made them prize their bitter life, yet stingily cut it short; who gave his angels eternal happiness unearned, yet required his other children to earn it; who gave is angels painless lives, yet cursed his other children with biting miseries and maladies of mind and body; who mouths justice, and invented hell--mouths mercy, and invented hell--mouths Golden Rules and foregiveness multiplied by seventy times seven, and invented hell; who mouths morals to other people, and has none himself; who frowns upon crimes, yet commits them all; who created man without invitation, then tries to shuffle the responsibility for man's acts upon man, instead of honorably placing it where it belongs, upon himself; and finally, with altogether divine obtuseness, invites his poor abused slave to worship him!”

--Mark Twain, No. 44, The Mysterious Stranger

“The best minds will tell you that when a man has begotten a child he is morally bound to tenderly care for it, protect it from hurt, shield it from disease, clothe it, feed it, bear with its waywardness, lay no hand upon it save in kindness and for its own good, and never in any case inflict upon it a wanton cruelty. God's treatment of his earthly children, every day and every night, is the exact opposite of all that, yet those best minds warmly justify these crimes, condone them, excuse them, and indignantly refuse to regard them as crimes at all, when he commits them. ”

-- Mark Twain, Letters from the Earth

Twain’s concern is not complicated. He reasoned that God could make the world a happy, loving place without hunger, disease and death. Twain then rails at the Lord for His utter failure to do so. We all agree that we, like him, see our world darkened too often by famine, pestilence, pain, suffering and death.

None of us would dare to address the deeply personal pain and loss that this man bore. Darwin buried a daughter too early, as did Descartes. All three of them turned against the Lord. None of us know how we might react. However, when he took on the very character of God, Twain missed a critical fact.

The God of Scripture did—in fact—create the very world Twain imagined
He should have!

In the beginning, we are told there was a perfect environment, with plenty to eat, and no sickness, striving, suffering or death. That is not just a Sunday School story, it is history. The Fall of sinful man ushered in the age of struggle, sickness and our own mortality.

The truly remarkable thing is that a Holy God, so rejected by his children, would sacrifice his Only Son to rescue them from the results of their own sin. That, actually, explains why we celebrate that baby in the manger, and His atoning death on the cross. Jesus came to undo what we did. You can spend your life being angry with God, if you wish--much like a spoiled child who rebels against a loving parent, who has provided sacrificially for him.

But God made a Way for you to come home to Him. This Christmas, before you read the Christmas story that solves the sin and death problem, please read Genesis 1-3, so you will know what the sin and death problem actually was. Who knows what would have been different in the lives of those three men who buried children too early, if they had. As they are all long dead, they know the Truth. If you are reading this, there is still time for you.

A $200,000 patio cover? Spokane man charged with insurance fraud

A Spokane man has been charged with insurance fraud and attempted theft after a snow-damaged patio cover worth about $4,000 mushroomed into a nearly $200,000 claim.

Keith R. Scribner, 47, was arraigned Monday in Spokane County Superior Court on one count of insurance fraud and one count of attempted theft.

In late July 2009, Scribner's mother, Marilyn Warsinske, filed a claim with Liberty Mutual insurance. She said a patio roof at a home she'd purchased had collapsed due to the weight of snow some 6 months earlier. The policy covered "like kind and quality" replacement. Her son, she told the company, would handle the claim.

Scribner told the insurance company that patio cover was an extensive structure, spanning the entire length of the patio and wrapping around the home's chimney. Claims officials, inspecting the site, wondered why was there no flashing or holes in the masonry. Scribner said that house painters must have made repairs.

He sent the insurance company three bids to replace the cover based on his description. The bids ranged from $195,586 to $213,815.

Claims officials asked Scribner for any photos of the roof prior to the damage or after it collapsed. Perhaps some were taken during a home appraisal prior to the purchase, they suggested. Scribner said there were no photos and was no appraisal.

But a claims handler discovered an aerial photo of the home on a real estate website. It showed a much smaller patio cover than Scribner claimed.

The company launched a fraud investigation and notified Insurance Commissioner Mike Kreidler's anti-fraud Special Investigations Unit.

As it turned out, there had been a home appraisal, the investigators discovered. In fact, Keith Scribner met with the appraiser. And the appraisal included photos of the patio cover. A real estate agent interviewed by investigators described the cover as being "small and nothing special or significant."

The home's previous owner also provided photographs of the structure. It was originally canvas. When that because troublesome to remove each year, the homeowner bought a polycarbonate cover. Cost: About $300.

An architect told a state fraud investigator that he'd met with Scribner in 2008 -- months before the snow collapse -- to discuss plans to replace the deck cover with new, larger one.

A local company, provided with measurements and photographs of the original structure, drew up replacement bids at the request of a state fraud investigator. The bids: $3,913 and $4,782.

Insurance problem? We can help

We're the state agency that regulates insurance in Washington state. If you're a Washingtonian, we're happy to help answer insurance questions and help try to solve problems with insurers/agents/etc.

What can you expect? If you file a complaint, for example, we will:

■ Contact the insurance company regarding your concerns, review their response, and share the results of our review with you.


■ Research and complete your complaint within 60 days.

■ Suggest steps you might take to resolve your issue.

■ Make your complaint a part of the company's public record.

■ Require the company to address your concerns and follow Washington state insurance laws and regulations.

And we get results. We get millions of dollars a year in delayed or denied claims paid to Washington consumers.

For a complete list of our customer service standards -- as well as links to easily file a complaint online -- please see our complaint help web page. You can also call our Insurance Consumer Hotline toll-free at 1-800-562-6900.

We'll try our best to help.

A Burning Need: Pay Attention to Insurance Coverage Policy Terms

Post by Ross Plyler
I read an interesting article in the Wall Street Journal Law Blog, “No Fire Fee? Let Your House Burn!" about a fire department in South Fulton, Tennessee that watched a house burn because the owners had not paid a $75.00 annual fire protection subscription fee. It should be noted that the South Fulton mayor promised the fire department would do everything it could to protect all human life, even if the person had not paid the fee. However, failure to pay means the homeowner is not entitled to firefighting services to protect real property, personal property or pets.  Incredibly, the article stated that in subscription-based systems, less than 70% of persons pay.
 
There is no doubt many local governments and special purpose districts are under financial pressure, but while the wisdom of such a policy is questionable, for our purposes, it raises interesting insurance questions.

It may be more of an underwriting concern as to whether the house sits in a subscription-based area. The risk of total fire loss likely rises exponentially if it is likely no one will even attempt to put out the fire. Also, coverage issues arise in this scenario. Could failure to pay the subscription be considered an “intentional act” that would be a basis for denying coverage? I guess the homeowner could always argue he did not intentionally fail to pay but was merely negligent in failing to do so. Certainly the insurer could argue that the homeowner’s failure to pay is a failure to mitigate his damages.

Practice Point: The best policy for insurers in these areas may be to have the homeowner certify that he will pay the subscription or be in direct violation of the policy terms. Thus, just like when the homeowner fails to pay his premium, if he fails to pay for fire service, the insurer could deny coverage. If the insurance company gets serious about this, banks and lenders would probably start requiring borrowers to escrow fire subscription services just like taxes and insurance premiums. Thus, the lender can be assured its collateral is safe from thus type of government policy or from a homeowner who intentionally or accidentally lets his fire subscription get cancelled.


Occupier’s Liability S.4(4)(f): Recreational Trail

In Turner v. Kitchener (City) [2011] O.J. No. 4803, the plaintiff was riding his bike along a recreational trail in Kitchener. It was his regular route and time of travel which put him on the trail at 5:15 am.

Earlier that day vandals had set fire to a bridge along the trail and after investigating, the police and fire personnel had blocked off the bridge with a wooden barricade and yellow caution tape.

The plaintiff was biking at a relatively high speed for the time of morning, was wearing a helmet but did not have any light affixed to his bike. As the plaintiff approached the barricade, he was not able to see it, and when he did notice it is was too late to stop safely. The plaintiff applied his brakes so hard that he flipped over the bike and suffered injuries.

In this case, the plaintiff must establish that the defendant acted with “reckless disregard” towards him.

The trail is a “recreational trail”, so that s.4(4)(f) of the Occupier’s Liability Act (“Act”) was triggered. Section 4(3)(c) of the Act is also triggered and the plaintiff is deemed to have willingly assumed all risks when he rode his bike on the trail that day.

The deputy trial judge cited Cormack v. Mara (Township) (1989), 68 O.R. (2d) 716 (C.A.) which defined “reckless disregard” as doing or omitting to do something which the occupier “should recognize as likely to cause damage or injury to [the person] present on his or her premises, not caring whether such damage or injury results”.

After the fire, police and fire personnel attended the scene the city dispatched a crew to erect an orange barrier with several lines of yellow caution tape blocking off bridge access. The bridge was blocked off in order to arrange an inspection to determine if the bridge was structurally safe.

The plaintiff’s expert report concluded that the city ought to have used either a reflective warning sign and/or a flashing beacon.

The city offered evidence that the recreational trails are closed between 11pm and 6am. There are signs posted which state this and there is a by-law which specifically prohibits presence in the park, including on the trails between those hours.

The deputy judge accepted the city’s evidence, although it only showed that the plaintiff was in violation of a city by-law. He held that the city did not act with “reckless disregard” for the plaintiff. The deputy judge further explained that,“it could not be deemed likely, from the city’s perspective, that a bicyclist riding a trail while it was closed, and more importantly, while it was almost completely dark, without a headlight, would fail to see the barricade until it was too late to stop safely. Nor do I find that the city did not care whether injury resulted from its erection of the barricade.”

The deputy judge also stated that a flashing light on the barricade would have increased the possibility of the plaintiff seeing the barrier, but that a light on his bike and riding at a slower speed in the dark would have done the same thing.

If the deputy judge had found for the plaintiff on liability, he would have reduced the damages by a factor of 70%.

Also see Kennedy v. London (City) (2009), 58 M.P.L.R. (4th) 244 (Ont S.C.J.) and Schneider v. St. Clair Region Conservation Authority (2009), 97 O.R. (3d) 81 (C.A.) on the issue of recreational trails.

- Alison McBurney

Cavalcade of Risk #145 is up

Take a look here for an excellent compilation of blog posts about risk.

Medicare drug and Advantage plan enrollment ends Dec. 7

Medicare's open enrollment for prescription drug plans (Part D) and Medicare Advantage plans ends Dec. 7.

This year's enrollment period was moved and expanded, thanks to the Affordable Care Act, giving people additional time to consider their choices.

Still need to make a decision and need some help? Our Statewide Health Insurance Benefit Advisors (SHIBA) program can answer questions and help you evaluate plans. Call our Insurance Consumer Hotline at 1-800-562-6900 and ask to make an appointment with a SHIBA volunteer in your area.

Before you make your decision, consider these tips:


  • Plan costs and coverage can change every year, so carefully review all letters and notices from your current plan.

  • Make a list of all current prescription drugs you take, the doses, and how often. Then, use the Plan Finder at www.medicare.gov to compare Part D plans.

  • Review the 2012 Medicare & You handbook. You should have received it in September.
    If you have questions, call 1-800- MEDICARE (1-800-633-4227) before you sign up.

  • If you have limited income and need help paying for prescription drugs, check out Medicare’s “Extra Help” program. To see if you qualify, contact the Social Security Administration at 1-800-772-1213 or go to www.socialsecurity.gov and click on Medicare.
But most importantly, don't wait! Remember, open enrollment ends Dec. 7. Here's a list of prescription drug plans and Medicare Advantage plans

WHY WE WILL LOOK SILLY

WHY WE WILL LOOK SILLY

Yesterday’s cutting edge technology, like the once-cool Sony Walkman, looks silly to today’s children who use iPods. Much of current technology will look silly to your future grandchildren, according to Shane Richmond and Ian Douglas who write for UK’s Telegraph newspaper. What follows are a few of the things that they and others predict will look silly to future generations. Actually, I think they are right.

TV schedules: That week-long wait for your favorite TV show was a familiar feature of my childhood. Remember cartoons on Saturday mornings? Now, TV is transforming into a demand-driven service. Watch whatever, whenever you want.

Recipe books: In the house of the future, your fridge will know exactly what food items it contains, and what meals you can make with those ingredients, while video panels embedded within the work surfaces will guide you through every stage of the cooking process.

Laptops: "I used to have to carry a separate bag for my computer," you'll find yourself explaining to some youngster as he unfolds his e-paper, touchscreen laptop, connects it to his cloud storage database and starts watching a film.

Cordless home phones: The phone used to be attached to the wall by a cable and, for some unknown reason, it would probably be in the hall, forcing you to sit on the stairs while you chatted. Then came the cordless phone. Isn't it great to be able to walk around the house while you're on the phone? Your kids already wonder why phones were ever “attached” to homes by a curly cord.

Glasses: Wearing glasses to correct vision problems is still a social norm but with laser eye surgery and contact lenses, it's not hard to imagine a point in the near future when they become obsolete. However, the concept of hanging lenses in front of your face has been around for centuries and is still pretty useful. Sunglasses will be around for a while and your children may start wearing glasses to take advantage of augmented reality services, for example for navigation.

Video and Audio tape: Tape is already a thing of the past in most homes. There's no need to remember to rewind a rental video before you return it. The language remains, however, and your children may wonder why you talk about "taping" a TV show when what you're actually doing is saving it to a hard drive on a Digital Video Recorder (DVR).

Photo processing: The idea that you'd have to shoot a whole roll of film holding, if you are lucky, 36 pictures, before you can see whether any of them were any good, sounds odd to the digital camera generation. Stranger still is the idea of taking your film to the drugstore - after snapping three pointless shots of your cat to finish the film - and then waiting an hour while they processed them.

Watches: You spend most of your time sitting in front of a computer that shows the time in the corner of the screen. When you're at home you can see the time on your DVD player and your oven. And when you're out and about you're carrying a mobile phone that displays the time. Admit it, your watch is just a piece of jewelry now, isn't it?

Keyboards: Many touchscreen devices still make a clicking noise when you type on them but there's no real reason to. Modern keyboards are very quiet - nothing like the thump of old typewriters or the clacking of keyboards from the 80s. But the keyboard itself may not last much longer. They take up space, adding to the bulk of portable devices, and they suffer from being fixed: a British keyboard cannot transform into a Russian one but a touchscreen can. Though touchscreens take some getting used to for those who have learned keyboards it's unlikely that those who grow up with them will have the same problem.

CDs, DVDs and Minidiscs: Physical media are constantly being replaced. The path from records to eight track cartridges to cassettes to CDs to minidiscs to MP3 players is littered with laser discs, digital audiotapes and HD-DVDs. They’re replaced now by wireless downloads to your watching or listening device. Your CD collection is already as outdated as your grandfather's library of Vinyl LP Albums!

Pagers: It required someone to call a number so that a message can be sent to you, to ask you to call them back - is nonsense. Don't even try to explain it to your children.

The map and compass: The time of the paper map and physical compass has already passed. Having a map in a device, such as a mobile phone, means that it can be updated when necessary and can be made interactive.

Black & white film and TV: The world of old used to be in black and white, at least that's how it appears to children.

Letters: The art of letter writing is being killed by the internet. However, it's not just the art, but the technology of letters that has been usurped. The idea of writing something, putting it in the mail, waiting for it to arrive and then waiting even longer for a reply seems bizarre in our world of always-on communications. Plane tickets, bank statements and bills are already paperless for most people.

Fax machines: Every now and again a piece of paper can't be emailed to someone and, as discussed above, the mail is just too slow. So we have to dust off the fax machine in the corner. This technology dates back to the 1970s.

Email: As we've seen already, email has replaced letters and the fax machine. But don't think being email-friendly means you can escape the mockery of your juniors. Teenagers these days eschew email in favor of instant messenger for direct communication and prefer social networks for longer messages.

Gas-powered vehicles: Our children may be slightly perplexed to hear that we used to pump flammable liquid into our cars to keep them running. They’ll be plugging theirs in instead.

Phone booths: Yes kids, we left phones lying around the country, in giant glass boxes with sticking doors that pinched your fingers. Whenever someone wanted to use one of these phones they had to pay, which meant needing to have change on you. Good luck finding a phone booth anywhere today. (Where would Superman change now?) In the future, life long phone numbers will soon be assigned to find you wherever, whenever, forever.

Multiple remote controls: We used to have to walk across the room to change the channel on the television that had only three channels anyway. Now we have four remotes. In future, your mobile phone will probably double as a remote for whatever it is you're trying to operate.

Floppy discs: From the 1969 eight-inch format, to the mid-1990s 3.5 inch plastic case, your children will be amazed to learn that at their best, they held up to 240MB. (A few songs’ worth on their iPod).

Telephone directories: We printed every phone number into a huge book, which we delivered to every household in the country! Seriously! (Now, few have home numbers anyway.)

Dial-up internet access: It will seem odd to future generations that we used to turn our internet access on --during which you couldn't use your phone– and be charged by the minute for access.

Computers in boxes: As components get smaller still and more computing power is transferred to the cloud, cutting the need for local resources, the need for a box will be eliminated altogether.

Visiting the supermarket: By the time your children are grown up, all of those boring products will be ordered online and delivered to save you the trouble of going to the shop and getting them.

‘Owning’ music, books and film: Once data can be stored in the cloud and accessed by your device whenever you need it, the idea of 'owning' something starts to seem strange. Your children won't collect albums, they'll have every album ever made at their fingertips all the time.

Cords and cables: Wireless data transfer, battery-powered devices and cordless charging mats will make the spaghetti of wires in every office as obsolete as going into or gas station to pay for gas.

TVs and radios that need tuning: "Stay tuned" lost its original meaning and your children will never guess that you used to turn a tiny dial like a safe cracker in an effort to get your TV tuned to the correct channel.

Disposable batteries: Mobile phones, laptops and MP3 players mostly use rechargeable batteries. The idea that you used to have to throw batteries away and then go and buy some new ones already seems quite strange.

Fillings in teeth: It's good to know that in the near future all that business with injections, numb mouths and metal amalgams will be over and old, damaged teeth will be removed and replaced with shiny news ones, grown from stem cells to order. The last generation to know the special fear that comes with the rising whine of the drill is already brushing its own teeth.

Road signs: Universal Satellite-navigation will mean they’ll be tearing down those hulking sheets of metal at the side of the road and insisting that your car informs you that it's five miles to town or that road works will be disrupting traffic until July 2035. Those same devices will also keep an eye on your speed and report your movements to the traffic police.

Checks: You probably laugh at these already, and your children will be laughing right along with you. Imagine, a booklet of pre-printed IOUs that you use instead of money. You hand out details that would allow the recipient to set up direct debits on your account with every payment. They are secured only by your signature, which the person processing the check has no chance of recognizing. Mobile phones will be swiped for payment at checkout (to get your right hand used to that motion?)



Mr. Peel, who is feeling older everyday, is a local attorney seeking justice for those hurt in motor vehicle accidents, work related injuries, medical malpractice, nursing home and trucking cases. Mr. Peel often addresses churches and clubs and can be contacted through www.PeelLawFirm.com, wherein other articles can also be found.

Massachusetts now bans personal auto insurers from using credit scores in setting rates

Property Casualty 360 discusses the development in this article.
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