On February 6, 2012, in Hartford Life & Annuity Ins. Co. v. Doris Barnes Family 2008 Irrevocable Trust, et al., the United States District Court for the Central District of California granted summary judgment on behalf of the Doris Barnes Family 2008 Irrevocable Trust and against Hartford Life and Annuity Insurance Company on all of Hartford’s claims, including a claim that the policy at issue was void for lack of insurable interest and claims for fraud, fraudulent inducement, negligent misrepresentation, and conspiracy.

The case involved the sale, shortly after the policy was issued, of the beneficial interest in the Trust, which was formed to purchase the policy. Hartford sought a declaration that the policy was void for lack of insurable interest because the insured, Doris Barnes, obtained the policy with the specific intent to sell it right away. Hartford also sought damages against the Trust for fraud and conspiracy based on misrepresentations that were allegedly made in connection with the application for the policy.

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