National General Premier Ins. Co. v. Haro CA2/8

BACKGROUND

In October 2020, Haro had an automobile insurance policy with National General which covered her 2017 Audi. She obtained this policy through Ezone. National General used Ezone to communicate with Haro, sending policy correspondence to Ezone to forward to Haro. In the policy it issued for the 2017 Audi, National General repeatedly referred to Ezone as a co-presenter of the policy, and directed Haro to contact Ezone if she had any questions about the policy. Ezone had authority to bind insurance instantly on behalf of National General.

2 On October 25, 2020, Haro purchased a 2020 Dodge Challenger as a second car. On Friday, November 6, 2020, Haro sent the following email to Ezone: “Hi Celeste, hope all is well. [C]an I please [g]et a quote for a auto policy on a 2020 Dodge Challenger? [¶] Let me know what other information you need.” Haro offered evidence that based on her past dealings with Ezone, this email would be treated as a request for a policy. In the past, when she asked them for a quote, she got a policy “in return.” Ezone replied and asked for the vehicle identification number (VIN) of the vehicle. On Monday, November 9, 2020, at 8:21 a.m., Haro emailed the…