A policy renewal requires a living insured to form a valid insurance contract, the Sixth Circuit recently ruled. In Boby Davis, et al. v. Westfield Ins. Co., Case No. 21-2797 (6th Cir. Mar. 14, 2022), Della Shields received a yearly homeowner’s insurance policy covering her home in Muskegon, Michigan from 2013 until her death in March 2018. Shields was the sole named insured in the yearly policy declarations. About The Authors