Hartford Underwriters Insurance Company v. Dave Henry Reed.

Summary

The Alabama Supreme Court held that Hartford properly cancelled the workers’ compensation policy under its contractual terms and therefore met its burden of proof, reversing the trial court’s denial of a judgment‑as‑a‑matter‑of‑law. The court distinguished Institute of London Companies v. Valley Equipment and affirmed that the mailbox rule creates a presumption of receipt for a properly mailed cancellation notice. The judgment for Reed was reversed and the case remanded.