Cases

A court of the Eastern District of Texas resolved multiple matters of first impression with Erie guesses, holding that equitable reformation is an appropriate remedy for an insurer’s failure to provide adequate and timely notice of a material policy change and that the insured’s failure to read subsequent policies that include the material change is not necessarily a bar to such remedy, but that the “conspicuous” requirement for notice can be met through brevity rather than contrast where the material changes are displayed in a one-page, 180-word letter.