Doctors' Company v. Insurance Corporation of America
In Doctors' Company v. Insurance Corporation of America, 864 P.2d 1018 (Wyo. 1993), the Court embraced the application of the promissory estoppel doctrine to instances involving insurance contracts.
In that case, the insured successfully asserted promissory estoppel to preclude an insurer from denying coverage when the insurer's retroactive coverage, without express exclusionary language, was an affirmative representation that coverage would be provided for the potential claim at issue.
The insured, a doctor, specifically informed the insurer in his application for insurance coverage of the circumstances surrounding a potential medical malpractice claim that could arise.
The insurer responded by issuing a policy with retroactive coverage and, in doing so, failed to expressly exclude coverage for the potential claim. 864 P.2d at 1029-30.