CNA International Reinsurance Co. v. Phoenix
Florida District Court of Appeal
678 So. 2d 378 (1996)
River Phoenix (defendant), through his company Jude Nile, entered actor-loanout agreements with two film production companies, Scala Productions and Geffen Pictures; both productions were insured by CNA International Reinsurance and American Casualty (plaintiffs). Phoenix died of a drug overdose before either film was completed, the insurers paid the productions and became subrogated to their claims, and sued Phoenix's estate, represented by his mother Arlyn, for breach of the loanout agreements; the trial court granted the estate's motion to dismiss.
Whether, under contract law, a personal-services contract is rendered impossible to perform by the death of the party obligated to perform the services.