A Wisconsin appeals court ruled that a notice of cancellation became effective ten days after the mailing of the notice, not after the receipt of the notice by the insured, in Schmitz v. Fire Insurance Exchange, No. 04-1545, 2005 WL 545301 (Wis. App. Mar. 9, 2005).

Robert Schmitz applied for a homeowners insurance policy through a Fire Insurance Exchange agent, Karen Paladino. Because Schmitz had submitted a prior claim on a previous policy, Paladino warned him that his application might be denied. She issued a binder for coverage anyway, and Schmitz paid premiums.