Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.
Eighth Circuit: Gerald E. Carlson v. Midwest Professional Planners
Torts
Claim against an insurance agent for not listing co-owners of policy doesn't state a claim, as the primary owner of the policy was the only one who could legally cure the omission.