reasonable expectations doctrine (Pennsylvania) · Go Syfert
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reasonable expectations doctrine in Pennsylvania

9 Pennsylvania opinions name it 4 courts 1986–2024 1 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Matcon Diamond, Inc. v. Penn National Insurancegreen
pasuperct · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024Co., 815 A.2d 1109, 1114 (Pa. Super. 2003), this Court explained the evolution of the reasonable expectations doctrine: This Court has noted that, generally, courts cannot invoke the reasonable expectation doctrine to create an ambiguity where the policy itself is unambiguous.

11
Vandenberg v. Superior Courtgreen
cal · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2007–2007
2 sentences

2007United’s amicus brief at 23, citing Vandenberg v. Superior Court, 21 Cal.4th 815 , 88 Cal.Rptr.2d 366 , 982 P.2d 229, 245 (1999). ¶46 This argument, however, also ignores the applicable rules of construction.

2007United’s amicus brief at 23, citing Vandenberg v. Superior Court, 21 Cal.4th 815 , 88 Cal.Rptr.2d 366 , 982 P.2d 229, 245 (1999). ¶46 This argument, however, also ignores the applicable rules of construction.

11
Fox v. 7L Bar Ranch Co.green
mont · 1982 · cited in 1 Pennsylvania opinions naming this issue, 2001–2001
1 sentence

2001See e.g., Capital Toyota Inc. v. Gerwin, 381 So.2d 1038, 1039 (Miss. 1980) (examining plaintiff’s reasonable expectations); Fox v. 7L Bar Ranch Co., 645 P.2d 929, 933 (Mont. 1982) (“[b]ecause of the special circumstances underlying closely held corporations, courts must determine the expectations of the shareholders concerning their respective roles in corporate affairs”); Brenner v. Berkowitz, 634 A.2d 1019, 1029 (N.J. 1993) (“[c]ourts also should consider whether the misconduct thwarts the minority shareholder’s reasonable expectations of his or her role in the corporation”); Landstrom v. Sh

11
Landstrom v. Shavergreen
sd · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2001–2001
1 sentence

2001See e.g., Capital Toyota Inc. v. Gerwin, 381 So.2d 1038, 1039 (Miss. 1980) (examining plaintiff’s reasonable expectations); Fox v. 7L Bar Ranch Co., 645 P.2d 929, 933 (Mont. 1982) (“[b]ecause of the special circumstances underlying closely held corporations, courts must determine the expectations of the shareholders concerning their respective roles in corporate affairs”); Brenner v. Berkowitz, 634 A.2d 1019, 1029 (N.J. 1993) (“[c]ourts also should consider whether the misconduct thwarts the minority shareholder’s reasonable expectations of his or her role in the corporation”); Landstrom v. Sh

11
Brenner v. Berkowitzgreen
nj · 1993 · cited in 1 Pennsylvania opinions naming this issue, 2001–2001
2 sentences

2001See Brenner v. Berkowitz, 634 A.2d 1019, 1029 (N.J. 1993) (“[cjourts also should consider whether the misconduct thwarts the minority shareholder’s reasonable expectations of his or her role in the corporation”).

2001See e.g., Capital Toyota Inc. v. Gerwin, 381 So.2d 1038, 1039 (Miss. 1980) (examining plaintiff’s reasonable expectations); Fox v. 7L Bar Ranch Co., 645 P.2d 929, 933 (Mont. 1982) (“[b]ecause of the special circumstances underlying closely held corporations, courts must determine the expectations of the shareholders concerning their respective roles in corporate affairs”); Brenner v. Berkowitz, 634 A.2d 1019, 1029 (N.J. 1993) (“[c]ourts also should consider whether the misconduct thwarts the minority shareholder’s reasonable expectations of his or her role in the corporation”); Landstrom v. Sh

11
Capitol Toyota, Inc. v. Gervingreen
miss · 1980 · cited in 1 Pennsylvania opinions naming this issue, 2001–2001
1 sentence

2001See e.g., Capital Toyota Inc. v. Gerwin, 381 So.2d 1038, 1039 (Miss. 1980) (examining plaintiff’s reasonable expectations); Fox v. 7L Bar Ranch Co., 645 P.2d 929, 933 (Mont. 1982) (“[b]ecause of the special circumstances underlying closely held corporations, courts must determine the expectations of the shareholders concerning their respective roles in corporate affairs”); Brenner v. Berkowitz, 634 A.2d 1019, 1029 (N.J. 1993) (“[c]ourts also should consider whether the misconduct thwarts the minority shareholder’s reasonable expectations of his or her role in the corporation”); Landstrom v. Sh

11
Reliance Insurance v. Moessnergreen
ca3 · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000In Reliance Insurance Co. v. Moessner, the appellate court considered an argument that the reasonable expectations doctrine does not apply to “sophisticated insureds.” Reliance Insurance Co., 121 F.3d at 904-908 .

2000The court predicted that Pennsylvania courts would “apply the reasonable expectations doctrine, regardless of whether the insured is sophisticated, if the insurer unilaterally inserts the contested provision in the insurance policy despite the insured’s request for coverage ....” Id. at 906 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
Collister v. Nationwide Life Insurance green
pa · 1978
2 sentences

2009The reasonable expectations doctrine substantially pre-dates Tonkovic, see Collister 388 A.2d at 1351 , and in the three decades since its adoption, our courts have applied the doctrine to a wide range of insurance cases, see e.g., Betz. 6 .

2003Co., 479 Pa. 579 , 388 A.2d 1346 (1978) "to protect non commercial insured from policy terms not readily apparent” and Tonkovic v. State Farm Mut.

31999–2009
cluster 398579 green
cadc · 1981
1 sentence

2014The court stated that under the reasonable expectations standard, the policies that were issued to Keene were for the purpose of relieving Keene “of the risk of liability for latent injury of which Keene could not be aware when it purchased the insurance.” Id. at 1047 .

12014–2014
Bianculli v. Turner Construction Co. green
pasuperct · 1994
2 sentences

2003Co., 433 Pa.Super. 237 , 640 A.2d 461 (1994), where the trial court was found to have abused its discretion in dismissing the cross-claim for indemnity, and the present case, where the indemnity claim was dismissed as being premature, to be addressed at a later time after a review of further issues.

2003Co., 433 Pa.Super. 237 , 640 A.2d 461 (1994), where the trial court was found to have abused its discretion in dismissing the cross-claim for indemnity, and the present case, where the indemnity claim was dismissed as being premature, to be addressed at a later time after a review of further issues.

12003–2003
Madison Construction Co. v. Harleysville Mutual Insurance green
pa · 1999
2 sentences

2003Co., 557 Pa. 595 , 735 A.2d 100 , 109 n. 8 (1999) noted that the reasonable expectations doctrine applied in Collister v. Nationwide Life Ins.

2003Co., 557 Pa. 595 , 735 A.2d 100 , 109 n. 8 (1999) noted that the reasonable expectations doctrine applied in Collister v. Nationwide Life Ins.

12003–2003
Young v. Ethyl Corp. green
scotus · 1979
2 sentences

1999Co., 479 Pa. 579 , 388 A.2d 1346 (1978) (applying doctrine to protect non-commercial insured from policy terms not readily apparent), cert. denied, 439 U.S. 1089 , 99 S.Ct. 871 , 59 L.Ed.2d 55 (1979); Tonkovic v. State Farm Mut.

1999Co., 479 Pa. 579 , 388 A.2d 1346 (1978) (applying doctrine to protect non-commercial insured from policy terms not readily apparent), cert. denied, 439 U.S. 1089 , 99 S.Ct. 871 , 59 L.Ed.2d 55 (1979); Tonkovic v. State Farm Mut.

11999–1999
Sworob v. Harris green
scotus · 1979
2 sentences

1999Co., 479 Pa. 579 , 388 A.2d 1346 (1978) (applying doctrine to protect non-commercial insured from policy terms not readily apparent), cert. denied, 439 U.S. 1089 , 99 S.Ct. 871 , 59 L.Ed.2d 55 (1979); Tonkovic v. State Farm Mut.

1999Co., 479 Pa. 579 , 388 A.2d 1346 (1978) (applying doctrine to protect non-commercial insured from policy terms not readily apparent), cert. denied, 439 U.S. 1089 , 99 S.Ct. 871 , 59 L.Ed.2d 55 (1979); Tonkovic v. State Farm Mut.

11999–1999
Taylor v. Phoenix Mut. Life Ins. Co. green
paed · 1978
1 sentence

1986Similarly, coverage was denied in Taylor v. Phoenix Mutual Life Insurance Co., 453 F.Supp. 372 (E.D.Pa.1978).

11986–1986
Kravitz v. Equitable Life Assur. Soc. of US green
paed · 1978
2 sentences

1986In Kravitz v. Equitable Life Assurance Society of the U.S., 453 F.Supp. 381 (E.D.

1986In Kravitz v. Equitable Life Assurance Society of the U.S., 453 F.Supp. 381 (E.D.

11986–1986
Weissman v. PRASHKER green
pa · 1961
2 sentences

1986As to when the reasonable expectations doctrine might be applied, the Court in Kravitz , went on to state, “Pennsylvania courts will rely on public policy and overriding explicit terms in the insurance contract, at least when the contract terms would operate to defeat the reasonable expectations of the insured.” Id. at 383 , citing Sands v. Granite Mutual Insurance Co., supra. In Kravitz , however, coverage was denied.

1986As to when the reasonable expectations doctrine might be applied, the Court in Kravitz , went on to state, "Pennsylvania courts will rely on public policy and overriding explicit terms in the insurance contract, at least when the contract terms would operate to defeat the reasonable expectations of the insured." Id. at 383 , citing Sands v. Granite Mutual Insurance Co., supra .

11986–1986
Standard Venetian Blind Co. v. American Empire Insurance green
pa · 1983
2 sentences

1986Further, if Pennsylvania has embraced the reasonable expectations doctrine, we question its state of health in view of Standard Venetian Blind Co. v. American Empire Co., supra. The court in Standard Venetian Blind, supra, stated that Hionis, supra, held, “ ‘Where a policy is written in unambiguous terms, the burden of establishing the applicability of the exclusion or limitation involved proof that the insured was aware of the exclusion or limitation, and that the effect thereof, was explained to him/ ” (Emphasis added.) Therefore, for the Hionis doctrine to be applicable, there must be a pol

1986Further, if Pennsylvania has embraced the reasonable expectations doctrine, we question its state of health in view of Standard Venetian Blind Co. v. American Empire Co., supra. The court in Standard Venetian Blind, supra, stated that Hionis, supra, held, “ ‘Where a policy is written in unambiguous terms, the burden of establishing the applicability of the exclusion or limitation involved proof that the insured was aware of the exclusion or limitation, and that the effect thereof, was explained to him/ ” (Emphasis added.) Therefore, for the Hionis doctrine to be applicable, there must be a pol

11986–1986

Where else courts name it

MN 37 (1985–2015) KY 31 (1987–2026) WV 25 (1987–2026) AZ 25 (1986–2020) NJ 19 (1986–2019) IL 18 (1988–2026) IA 18 (1975–2022) OK 14 (1996–2022) MT 12 (1993–2018) ID 11 (1975–2026) CA 10 (1983–2026) MA 10 (1984–2012) PA 9 (1986–2024) MI 9 (1994–2015) NM 7 (1977–2013) CO 7 (1996–2025) UT 7 (1992–2015) WA 6 (1994–2019) SC 6 (2001–2014) DE 6 (2015–2026) MO 6 (1987–2024) AL 6 (1993–2009) CT 5 (1987–2019) OH 5 (1986–2020) KS 4 (2002–2019) FL 4 (1996–2025) MD 3 (2015–2023) ND 3 (1977–2000) DC 3 (2001–2017) AK 2 (1996–2025) TX 2 (2013–2014) NC 2 (1996–2014) LA 2 (1995–2020) NH 2 (1978–1980)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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