Mills

Defendant insurance company denied uninsured motorist coverage to a third party beneficiary injured in an automobile accident because it had cancelled the policy before the accident occurred. The third party sued, and the insurer sought summary judgment. The third party opposed, contending the cancellation was invalid because a written notice seeking information sent by the insurer to the insureds prior to cancellation was unreasonable as a matter of law, and disputed facts existed as to whether the insurer had mailed the notice of cancellation and actually cancelled the policy. The trial court granted summary judgment, and we affirm.

FACTS AND PROCEDURAL HISTORY

California law grants an insurer the right to cancel an automobile insurance policy prior to its expiration due to “a substantial increase in the hazard insured against.” (Ins. Code, § 1861.03, subd. (c)(1).)

A “substantial increase in the hazard insured against” occurs when, among other events, the insured refuses or fails to provide the insurer, “within 30 days after reasonable written request to the insured, information necessary to accurately underwrite or classify the risk.” (Cal. Code Regs., tit. 10, §…