Lunardi v. Great-West Life Assurance Co

In Lunardi v. Great-West Life Assurance Co. (1995) 37 Cal.App.4th 807, an applicant for life insurance failed to disclose that he had been diagnosed with leukemia. (Id. at pp. 814-817.) On appeal, the plaintiffs argued that Insurance Code section 332 did not apply because the insurer had required a physical examination (see Lunardi, at p. 815) but had not required a complete blood count, which would have revealed the leukemia. (Id. at pp. 825-826.) The appellate court disagreed, stating: "Insurance Code section 332 does not require the insurer to take all possible measures to reveal undisclosed conditions." (Id. at p. 826.)