Armstrong v. Safeco Insurance

This case presents an issue of first impression concerning an insurer's refusal to renew an auto policy. RCW 48.18.292(1) requires an insurer which does not renew to give 20 days' notice to the insured and to include the actual reason for refusal to renew.

Jack C. Armstrong, the insured under an auto policy, contends that the statutory requirement of "the actual reason" for nonrenewal requires a reason based upon good cause. Safeco Insurance Company argues that the question *256is entirely legal and the "actual reason is all the statute requires." We summarize the facts which support Armstrong's…