Foremost Insurance v. Allstate Insurance

We granted leave to appeal to resolve a conflict in the Court of Appeals1 over whether a *381lienholder may recover under a loss payable clause where the insured breached an insurance contract, by intentionally destroying his property and misrepresenting the loss to his insurer.2 In cases involving nearly identical loss payable clauses, two Court of Appeals panels agreed that a standard loss payable clause operates as a separate contract of insurance between the lienholder and the insurer, yet differed over the coverage conferred upon the lienholder.3 The Boyd Court concluded that a lienholder’s…