California Supreme Court
Samuel Heckart, Plaintiff and Appellant v. A-1 Self Storage, Inc., Defendants and Respondents.
April 23, 2018231 Cal. Rptr. 3d 459
Summary
The court held that A-1's Protection Plan is not insurance subject to regulation under the Insurance Code. Article 16.3 regulates self-storage facilities acting as agents for licensed insurers, while A-1's plan was an indemnity agreement between A-1 and its renters. Applying the principal-object-and-purpose test, the court concluded that indemnification was incidental to the parties' principal transaction, the rental of storage space, and affirmed dismissal of the plaintiff's claims.