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Travelers Property Casualty Co. of America v. Keluco General Contractors, Inc.

INSURANCE LAW
Supreme Court of Alaska (2025)
Mike Galane

In Travelers Property Casualty Co. of America v. Keluco General Contractors, Inc., 572 P.3d 537 (Alaska 2025), the Supreme Court of Alaska held that insurance companies’ internal procedures to record mailings do not satisfy the United States Postal Service (USPS) certification requirements under Alaska Statute § 21.36.260. (Id. at 543). Travelers Property Casualty Co. of America (Travelers) issued a workers’ compensation insurance plan to Keluco General Contractors (Keluco) in March 2016 that was to expire in March 2017. (Id. at 539). In January 2017, Travelers mailed to Keluco a renewal notice in advance of its policy expiration. (Id.). Travelers internally recorded the January 2017 renewal notice through a USPS Form 3877 and an internal affidavit. (Id. at 542). Travelers did not seek a certificate or other verification of mailing from USPS. (Id. at 543). The letter never reached Keluco. (Id.). Consequently, Keluco did not renew its workers’ compensation insurance, and only realized its policy had lapsed when an injured Keluco worker sought to file a claim with Travelers against Keluco (Id.). Keluco brought suit that Travelers had failed to send notice of nonrenewal in accordance with Alaska Statute § 21.36.260. Travelers argues that their internal procedures—which were submitted to USPS but required no verification by USPS—satisfied the mailing notice requirement under Alaska Statute § 21.36.260. (Id. at 540). The Supreme Court of Alaska held that Travelers’ internal recording procedures did not fulfill the renewal notice requirements in Alaska Statute § 21.36.260. (Id. at 543). The Alaska Legislature amended Alaska Statute § 21.36.260 in 1987 to clearly require insurers to obtain a mailing certificate from USPS when sending renewal notices to clients. (Id.). Travelers’ internal procedures cannot be deemed equivalent to obtaining a certificate mailing from USPS (Id.). Accordingly, the Supreme Court of Alaska affirmed the trial court, holding that insurance companies’ internal procedures to record mailings do not satisfy the United States Postal Service (USPS) certification requirements under Alaska Statute § 21.36.260. (Id.).

Travelers Property Casualty Co. of America v. Keluco General Contractors, Inc.

INSURANCE LAW
Supreme Court of Alaska (2025)
Mike Galane

In Travelers Property Casualty Co. of America v. Keluco General Contractors, Inc., 572 P.3d 537 (Alaska 2025), the Supreme Court of Alaska held that insurance companies’ internal procedures to record mailings do not satisfy the United States Postal Service (USPS) certification requirements under Alaska Statute § 21.36.260. (Id. at 543). Travelers Property Casualty Co. of America (Travelers) issued a workers’ compensation insurance plan to Keluco General Contractors (Keluco) in March 2016 that was to expire in March 2017. (Id. at 539). In January 2017, Travelers mailed to Keluco a renewal notice in advance of its policy expiration. (Id.). Travelers internally recorded the January 2017 renewal notice through a USPS Form 3877 and an internal affidavit. (Id. at 542). Travelers did not seek a certificate or other verification of mailing from USPS. (Id. at 543). The letter never reached Keluco. (Id.). Consequently, Keluco did not renew its workers’ compensation insurance, and only realized its policy had lapsed when an injured Keluco worker sought to file a claim with Travelers against Keluco (Id.). Keluco brought suit that Travelers had failed to send notice of nonrenewal in accordance with Alaska Statute § 21.36.260. Travelers argues that their internal procedures—which were submitted to USPS but required no verification by USPS—satisfied the mailing notice requirement under Alaska Statute § 21.36.260. (Id. at 540). The Supreme Court of Alaska held that Travelers’ internal recording procedures did not fulfill the renewal notice requirements in Alaska Statute § 21.36.260. (Id. at 543). The Alaska Legislature amended Alaska Statute § 21.36.260 in 1987 to clearly require insurers to obtain a mailing certificate from USPS when sending renewal notices to clients. (Id.). Travelers’ internal procedures cannot be deemed equivalent to obtaining a certificate mailing from USPS (Id.). Accordingly, the Supreme Court of Alaska affirmed the trial court, holding that insurance companies’ internal procedures to record mailings do not satisfy the United States Postal Service (USPS) certification requirements under Alaska Statute § 21.36.260. (Id.).