P sued to recover on a policy of safe burglary insurance which required that the entry into the safe must have been "made by force and violence of which there shall be visible marks made by tools . . . or other chemicals." P's employee was forced to open the safe, after having been struck on the head with a gun, and in so doing the employee left blood stains on the safe. P contended that the policy was ambiguous in its terms and that the blood on the safe, having chemical qualities, demonstrated the use of chemicals to open the safe, as required by the policy. The trial court entered judgment for the defendant. Held, that blood was not a chemical within the meaning of the policy and that the policy was not ambiguous in its terms. Bridge v. Massachusetts Bonding & Insurance Co., 302 Ill. App. 1, 23 N. E. (2d) 367 (1939).
W. W. Kent,
INSURANCE -WHAT CONSTITUTES "MARKS OF FORCE AND VIOLENCE" WITHIN THE MEANING OF A POLICY OF SAFE BURGLARY INSURANCE?,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol38/iss8/18