Steven Zannini v. Phenix Mutual Fire Insurance Company

Summary

The Supreme Court of New Hampshire affirmed the Superior Court's grant of summary judgment for Phenix Mutual, holding that the policy's one‑year limitation provision does not violate public policy, is not unreasonable, and that the parties' communications did not toll, estop, or waive the limitation. The court reasoned that a shorter contractual period does not undermine the legislature's purpose of preventing stale claims and that the communications were insufficient to create factual disputes on tolling, estoppel, or waiver.