Code of Alabama

Ala. Code § 27-14-9 (2026)

Forms - Grounds for Disapproval or Withdrawal of Previous Approval.

✓ official Alabama Legislature (ALISON) text, current July 2026
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The commissioner may disapprove any form filed under Section 27-14-8 or withdraw any previous approval thereof only if the form:

(1) Is in any respect in violation of, or does not comply with, this title;

(2) Contains or incorporates by reference, where such incorporation is otherwise permissible, any inconsistent, ambiguous, or misleading clauses or exceptions and conditions which deceptively affect the risk purported to be assumed in the general coverage of the contract;

(3) Has any title, heading, or other indication of its provisions which is misleading;

(4) Is printed, or otherwise reproduced, in such manner as to render any provision of the form substantially illegible; or

(5) Contains provisions which are unfair, or inequitable, or contrary to the public policy of this state or which would, because such provisions are unclear or deceptively worded, encourage misrepresentation.

(Acts 1971, No. 407, p. 707, §322.)

Notes of Decisions
Cited in 7 cases, 1983–2013 · leading case: Dickerson v. Alexander Hamilton Life Ins. Co. of Am., 130 F. Supp. 2d 1271 (N.D. Ala. 2001).
Dickerson v. Alexander Hamilton Life Ins. Co. of Am., 130 F. Supp. 2d 1271 (N.D. Ala. 2001). · cites it 6× “Plaintiffs additionally argue that their claims made pursuant to Ala.Code § 27-14-9 are exempt from ERISA due to the ERISA savings clause found in 29 U.”
Allen v. State Farm Fire & Cas. Co., 59 F. Supp. 2d 1217 (S.D. Ala. 1999). · cites it 4× “Ala. Code § 27-14-9 . 14. Expressly included in the commissioner’s general supervisory powers is the power to hold hearings to decide issues pertaining to the insurance industry.”
State Farm Fire & Cas. Co. v. Slade, 747 So. 2d 293 (Ala. 1999). “See § 27-14-9, Ala.Code 1975 (stating that "[t]he commissioner may disapprove any [insurance policy] filed under Section 27-14-8 [(which includes a property-insurance policy)] or withdraw any previous approval thereof only if the [policy].”
Peacock v. Cincinnati Ins. Co., 51 So. 3d 298 (Ala. 2010). “Section 27-14-9, Ala.Code 1975, authorizes the commissioner to disapprove any such form if the form: “(1) Is in any respect in violation of, or does not comply with, [the Insurance Code]; “(2) Contains or incorporates by reference, where such incorporation is otherwise…”
Wixom Bros. Co. v. Truck Ins. Exch., 435 So. 2d 1231 (Ala. 1983). “The majority's disapprobation was made additionally manifest by the concluding paragraph of its opinion: "If, in the future, the Commissioner of Insurance because of limitations of manpower and time is not able to cause filed forms of policies of insurance to be scrutinized…”
Alabama Mut. Ins. Corp. v. City of Vernon, 178 So. 3d 350 (Ala. 2013). “Section 27-14-9, Ala.Code 1975, authorizes the commissioner to disapprove any such form if the form:' “ ‘(1) Is in any respect in violation of, or does not comply with, [the Insurance Code]; “‘(2) Contains or incorporates by reference, where such incorporation is otherwise…”
B & S Underwriters, Inc. v. Clarendon Nat'l Ins., 892 F. Supp. 815 (W.D. La. 1995). “” Ala.Code § 27-14-9(5) provides the insurance commissioner with broad powers to disapprove of forms that are contrary to the public policy of Alabama.”
— Ala. Code § 27-14-9(5) — 3 cases
Allen v. State Farm Fire & Cas. Co., 59 F. Supp. 2d 1217 (S.D. Ala. 1999). “Ala. Code § 27-14-9 . 14. Expressly included in the commissioner’s general supervisory powers is the power to hold hearings to decide issues pertaining to the insurance industry.”
Wixom Bros. Co. v. Truck Ins. Exch., 435 So. 2d 1231 (Ala. 1983). “The majority's disapprobation was made additionally manifest by the concluding paragraph of its opinion: "If, in the future, the Commissioner of Insurance because of limitations of manpower and time is not able to cause filed forms of policies of insurance to be scrutinized…”
B & S Underwriters, Inc. v. Clarendon Nat'l Ins., 892 F. Supp. 815 (W.D. La. 1995). “” Ala.Code § 27-14-9(5) provides the insurance commissioner with broad powers to disapprove of forms that are contrary to the public policy of Alabama.”
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