How can an insurer defend against a breach of contract claim by showing that the policy is void under a fraud or concealment clause?

In California, an insurer may defend against a breach of contract claim by showing that the insurance policy is void under a fraud or concealment clause. See Cummings v. Fire Ins. Exchange, 202 Cal. App. 3d 1407, 1416-17 (1988); see also Leasure v. MSI Ins. Co., 65 Cal. App. 4th 244, 248 (1998). A fraud or concealment clause voids a policy if a material misrepresentation is "knowingly and willfully made, with intent to deceive the insurer." Cummings, 202 Cal. App. 3d at 1416 (quoting

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Claflin v. Commonwealth Ins. Co., 110 U.S. 81, 95 (1884)).