Crnkovich v. Columbus Life Insurance

Crnkovich sued Columbus Life Insurance Company, Inc. (Columbus) in an effort to rescind a $100,000 universal life insurance policy, for which the premium was fully paid, on the ground that Columbus did not possess a certificate of authority to transact insurance in Idaho when it issued the policy to Crnkovich.1 The district court granted summary judgment dismissing the action, and Crnkovich appeals. We reverse and remand the case for further proceedings.

I

FACTUAL AND PROCEDURAL BACKGROUND

Crnkovich, an Idaho resident, obtained a $1,000,000 term life insurance policy in 1992 from Columbus…