Background
Dale and Janice Miner obtained a home-equity line of credit from GreenState Credit Union in 2019 and elected joint coverage under its optional Paybreak Debt Protection Plan. The plan would cancel a covered borrower’s outstanding loan balance upon death, but required each applicant to be under age seventy and excluded death benefits occurring on or after a protected borrower’s seventieth birthday.
Janice, who was seventy-three when she signed the application, died in 2020. The plan administrator denied the claim, citing her ineligibility at application and directed that the coverage be changed to Dale-only coverage. Dale sued GreenState for breach of contract, misrepresentation, fiduciary-duty breach, bad faith, and punitive damages. The district court granted GreenState summary judgment based on equitable rescission and, alternatively, the plan’s age exclusion.
The Court’s Holding
The Iowa Court of Appeals affirmed. Dale did not preserve his arguments that the district court improperly converted the action at law into an equitable matter or violated his jury-trial right. GreenState had raised equitable rescission in its summary-judgment brief, Dale did not object below, and he filed no post-ruling motion seeking a decision on those issues.
Independently, the court held that the undisputed age exclusion entitled GreenState to judgment as a matter of law. Janice died after age seventy, and the plan expressly excluded benefits for deaths occurring on or after that birthday. She also was ineligible when she applied because she was already over seventy. The asserted disputes about the closing, whether the Miners read the documents, and the handling of their driver’s licenses were not material to those dispositive facts.
Key Takeaways
- An unchallenged, unambiguous age exclusion can independently support summary judgment where the insured’s age and date of death are undisputed.
- Constitutional and equitable-procedure arguments must be raised and decided in the district court to be reviewed on appeal.
- Iowa’s rule concerning accepted premiums after a debtor correctly states her age did not apply because Janice’s signed certification that she was under seventy was false.
Why It Matters
The decision underscores that coverage disputes can be resolved on clear policy exclusions even when the parties contest surrounding sales or enrollment circumstances. It also illustrates Iowa’s strict error-preservation requirements: a party must object in the district court and, when necessary, seek a post-ruling determination before pursuing an appellate challenge.