Royal-Globe Insurance Co. v. Craven
Supreme Judicial Court of Massachusetts
585 N.E.2d 315 (Mass. 1992)
Craven (defendant) was hospitalized 23 days after a hit-and-run accident, recovered enough within a week of release to resume normal activities, returned to work about three months post-accident, but did not notify her insurer, Royal-Globe (plaintiff), of her claim until roughly four months after the accident. Her policy required notice within 24 hours for hit-and-run accidents but only "prompt" notice otherwise; after Royal-Globe denied her claim and Craven sought arbitration, Royal-Globe sued for a declaratory judgment of non-liability, and the trial court granted Craven summary judgment.
Whether notice of an accident given to an insurer four months after the accident, and over three months after the claimant's hospital release, is prompt.