## Facts

- Connecticut Mutual Life Insurance Company issued a life insurance policy on Dr. Samuel Beach.
- Dr. Beach died from injuries sustained in an accident involving the New York and New Haven Railroad Company.
- Connecticut Mutual paid (or became obligated to pay) the policy proceeds to the beneficiaries after Beach’s death.
- The insurer brought an action on the case against the railroad seeking damages equal to the policy amount, alleging the railroad’s wrongful conduct caused the death and the insurer’s resulting financial loss.
- The insurer sued in its own name for its own economic loss, not as a representative of the decedent, not under a wrongful-death statute, and not based on an asserted right of subrogation.

## Issues

1. Whether a life insurer that pays (or is obligated to pay) policy proceeds may maintain a direct tort action in its own name against a third party whose wrongful act caused the insured’s death to recover the amount paid.
2. Whether, absent statute or contractual/equitable subrogation, tort law recognizes a claim by a party suffering only derivative economic loss from another’s death.

## Decision

- The Supreme Court of Errors of Connecticut affirmed judgment for the railroad.
- The court held the insurer had no independent common-law cause of action against the alleged tortfeasor based solely on the insurer’s contractual payout.
- The court rejected recovery in the insurer’s own name where the insurer was neither a wrongful-death plaintiff designated by law nor a subrogee of the decedent’s rights.

## Legal Principles

- Payment of life insurance proceeds does not, by itself, create a tort claim in favor of the insurer against a third-party wrongdoer who caused the insured’s death.
- Tort law generally does not allow recovery for purely derivative economic loss by third parties whose injury is contingent on a contract with the person harmed.
- Wrongful-death recovery is limited to persons or entities authorized by statute or otherwise recognized by law; an insurer is not automatically within that class.
- Subrogation is not presumed for life insurers upon payment of policy proceeds absent a contractual provision or an established equitable basis extending to the claim asserted.

## Conclusion

The court denied a life insurer’s attempt to recover its policy payout from an alleged negligent tortfeasor, holding that the insurer’s loss was contractual and too remote for an independent tort remedy absent statutory authorization or a valid subrogation right.


Conn. Mut. Life Ins. Co. v. N.Y. & N.H.R.R. Co., 25 Conn. 265 (Conn. 1856)