๐Ÿ‡จ๐Ÿ‡ฆ Manulife's Third-Quarter Core Earnings Rise 4% to C$2.1 Billion and Core EPS Hits a Record C$1.24, While Reported Net Income Falls to C$1.4 Billion on Market Losses โ€” Manulife Financial Corporation (third-quarter 2026 press release, Form 6-K filed with the SEC, November 4, 2026)๐Ÿ‡จ๐Ÿ‡ฆ Sun Life's Third-Quarter Underlying Net Income Rises 9% to C$1.15 Billion, but Reported Net Income Falls 29% to C$785 Million and Wealth Outflows Reach C$32.7 Billion โ€” Sun Life Financial Inc. (third-quarter 2026 results release, Form 6-K filed with the SEC, November 4, 2026)๐Ÿ‡บ๐Ÿ‡ธ Aflac's Third-Quarter Net Earnings Drop to $303 Million After $1.1 Billion of Portfolio-Repositioning Losses, While Adjusted EPS Edges Down 2.4% to $2.43 and Japan's Margin Narrows โ€” Aflac Incorporated (third-quarter 2026 earnings release, SEC Exhibit 99.1, November 4, 2026)๐Ÿ‡บ๐Ÿ‡ธ Prudential Financial's Third-Quarter Adjusted Operating Income Falls to $1.32 Billion as the Prudential of Japan Sales Suspension Cuts Japan Earnings 25% โ€” Prudential Financial, Inc. (third-quarter 2026 earnings release, SEC Exhibit 99.1, November 3, 2026)๐Ÿ‡บ๐Ÿ‡ธ Lemonade's Third-Quarter In-Force Premium Jumps 34% to $1.55 Billion and Revenue Rises 73% to $336 Million, With the Net Loss at $43.7 Million and a Positive-EBITDA Quarter Promised for Q4 โ€” Lemonade, Inc. (third-quarter 2026 shareholder letter, Form 8-K exhibit filed with the SEC)๐Ÿ‡บ๐Ÿ‡ธ Corebridge Financial's Third-Quarter Operating EPS Rises 27% to $1.22 as the Share Count Falls 17%, With the Equitable Merger Reported to Be Making 'Significant Progress' โ€” Corebridge Financial, Inc. (third-quarter 2026 earnings press release, Form 8-K, November 2, 2026)๐Ÿ‡บ๐Ÿ‡ธ Jackson Financial's Third-Quarter Adjusted Operating Earnings Rise to $517 Million as Record RILA Sales of $3.0 Billion Lift Retail Annuity Sales 22% โ€” Jackson Financial Inc. 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(third-quarter 2026 shareholder letter, Form 8-K exhibit filed with the SEC)๐Ÿ‡บ๐Ÿ‡ธ Corebridge Financial's Third-Quarter Operating EPS Rises 27% to $1.22 as the Share Count Falls 17%, With the Equitable Merger Reported to Be Making 'Significant Progress' โ€” Corebridge Financial, Inc. (third-quarter 2026 earnings press release, Form 8-K, November 2, 2026)๐Ÿ‡บ๐Ÿ‡ธ Jackson Financial's Third-Quarter Adjusted Operating Earnings Rise to $517 Million as Record RILA Sales of $3.0 Billion Lift Retail Annuity Sales 22% โ€” Jackson Financial Inc. (third-quarter 2026 earnings release, SEC Exhibit 99.1)๐Ÿ‡จ๐Ÿ‡ฆ Fairfax Financial's Third-Quarter Net Earnings Fall to $1,097 Million as an $859 Million Investment Loss Offsets Higher Insurance Revenue and a Stronger Underwriting Result โ€” Fairfax Financial Holdings Limited (third-quarter 2026 interim report, Form 6-K filed with the SEC)๐Ÿ‡ฆ๐Ÿ‡บ A Magnitude 4.9 Earthquake Off South Australia Shook Adelaide: What Australian Home Insurance Covers and Why Earthquake Deductibles and Aftershock Clauses Matter โ€” Insurance Business Australia (reporting Geoscience Australia and insurance commentary)๐Ÿ‡ฎ๐Ÿ‡ณ SBI Life's First-Half FY27 Profit Rises 17% to Rs 1,270 Crore and Value of New Business Climbs 19% to Rs 3,270 Crore, While Costs Take a Larger Share of Premium โ€” Kotak Neo (report on SBI Life Insurance's H1 FY27 results)
Auto insurance policy and legal gavel representing court ruling on coverage (illustrative)
Auto Insurance๐Ÿ‡บ๐Ÿ‡ธUnited States

Michigan Supreme Court Backs Progressive's Rescission of an Auto Policy Over a Garaging Misstatement, Ruling Unanimously for the Insurer

PolicyRix Editorialยทยท8 min read
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On April 20, 2026 the Michigan Supreme Court unanimously held that a trial court abused its discretion by reforming rather than rescinding a Progressive no-fault policy where the insured misstated where her cars were garaged.

A mistake about where a car is kept can cost a driver their auto insurance, according to a unanimous decision of the Michigan Supreme Court. On April 20, 2026, the court ruled in a case brought by Janice Sherman against Progressive that a trial court had abused its discretion by reforming an auto policy instead of allowing the insurer to rescind it. The decision was reported on April 22 by Insurance Business, whose report this article summarises. An earlier version of this article described the case as one about driver misstatements in general. The court's decision is specifically about a misstatement of the garaging address, and the article now says so. This is a summary of a news report and not legal advice, and the formal opinion should be consulted for exact wording.

What were the facts? In November 2020, Janice Sherman bought a Michigan no-fault auto policy from Progressive covering a Cadillac and a Chrysler. Her application listed Clinton Township as her home address and as the garaging location, and identified herself as the sole resident and driver. She did not update the information when she renewed six months later. In July 2021, she was injured as a passenger in an insured vehicle when a hit-and-run driver struck it, and she filed a claim for personal protection insurance (PIP) benefits, the no-fault coverage that pays medical and related costs. Progressive's investigation found that the cars were garaged in Detroit, not Clinton Township. She lived in Detroit with her adult son, and one vehicle was garaged at her brother's home. None of this had been disclosed. Sherman said that her Detroit home was flooded and uninhabitable when she applied, that an agent completed the application, and that she never meant to defraud anyone. Progressive's underwriting specialist calculated that accurate information would have raised her premium by 83.2%.

What happened in the lower courts? Progressive denied the claim, rescinded the policy from the start, and refunded $1,491.54 in premiums. Sherman sued for benefits and breach of contract. The trial court denied Progressive's motion for summary disposition and ordered the policy reformed to a Detroit address, with Sherman required to repay the refund plus an additional premium, a total of $2,617.65. The Court of Appeals unanimously reversed. It held that the trial court erred in ordering reformation when the policyholder, not the insurer, engaged in misconduct. It vacated and reissued its opinion to clarify its reasoning, reaching the same result.

What did the Supreme Court decide? There were three holdings. First, on the standard of review, appellate courts reviewing a trial court's decision about rescission apply an abuse-of-discretion standard, not de novo review. This resolved confusion in lower courts, which had earlier applied a clear-error standard in a similar context. Second, the trial court abused its discretion, because the equities favoured Progressive: Sherman made material misrepresentations, Progressive relied on them, Progressive did nothing wrong, and no third-party interests were involved. Third, the court rejected Sherman's request for a new equities review by the trial court, distinguishing earlier cases where a remand was proper because no rescission analysis had been done. Six justices participated, and Justice Zahra wrote the opinion. Justice Noah Hood did not take part because he had sat on the Court of Appeals panel.

What does the ruling mean in practice? Under Michigan law, as described in the report, rescission is available when an applicant gives materially inaccurate information that the insurer relied on, regardless of intent. That means an honest mistake can still be material. The article stresses that rescission is not automatic: courts must weigh the equities, and the result could differ where the insurer's own conduct is at issue, for example where third parties such as an injured passenger's insurer or a medical provider have interests. The report does not identify a specific statute, and we do not name one.

Why does garaging matter? Insurers set rates partly by where a vehicle is kept, because theft, accident and claim costs differ by location. Michigan's auto market is known for high premiums in some areas. A difference of 83.2% in the premium, as Progressive calculated here, illustrates why insurers treat the address as material.

What should drivers do? Give accurate information about where each car is kept and who lives in the household, and update the insurer when circumstances change, including at renewal. If an agent completes an application, check it before signing. If something was wrong, correct it promptly. Misstatements can lead to rescission, denial of claims and loss of cover, which may be costly if injuries occur. Drivers with questions can ask their insurer or consult a lawyer or the state's insurance regulator.

This article is general information based on a news report of a court decision. It is not legal advice, and outcomes depend on the facts of each case.

Key Points

  • 1The Michigan Supreme Court decided Janice Sherman's case against Progressive on April 20, 2026, unanimously, in an opinion by Justice Brian K. Zahra; Justice Noah P. Hood did not participate.
  • 2Janice Sherman listed Clinton Township as her address and garaging location, but her cars were garaged in Detroit; Progressive's underwriter calculated accurate information would have raised her premium by 83.2%.
  • 3After a 2021 hit-and-run injury and PIP claim, Progressive denied the claim, rescinded the policy and refunded $1,491.54; the trial court reformed the policy to a Detroit address, but the Court of Appeals reversed.
  • 4The Supreme Court held that appellate review of a trial court's rescission decision is for abuse of discretion, and that the trial court abused it because the equities favoured Progressive.
  • 5Under Michigan law, rescission is available for materially inaccurate information the insurer relied on, regardless of intent, but it is not automatic: courts must weigh the equities.

Why This Matters

Where a car is garaged is a major rating factor in Michigan's expensive auto market. The ruling shows that a misstatement on an application can cost an injured insured their coverage, even if it was not intended to deceive.

#michigan supreme court#progressive#rescission#garaging#no-fault#misrepresentation
Disclaimer: This article is for informational purposes only and does not constitute financial, investment, legal, or insurance advice. Always consult a qualified professional before making financial decisions. PolicyRix reports on publicly available information from third-party sources and cannot guarantee the accuracy or completeness of such information.

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