Adrienne Siddens v. Philadelphia Indemnity Insurance Company, WD84141

Decedent, an employee of Ultramax Events, LLC (an entity listed on the Policy schedule), was struck and fatally injured by an uninsured motorist while loading cones into an Ultramax truck after a race.
Ultramax was insured under a Philadelphia Indemnity Insurance Company (PIIC) commercial automobile policy that names "USA Track & Field Event Directors" as the Named Insured; Ultramax is one of the listed Event Directors.
An Amendment to the Policy’s UM endorsement expressly adds "Event Directors . . . and their respective employees, volunteers or any other permissive user while using a covered auto with permission from a covered event director" to the class of insureds.
The policy provides $1,000,000 UM coverage per covered auto; seven covered autos existed, so an individual Named Insured could potentially "stack" to obtain $7,000,000.
Siddens (Decedent’s wife) sought stacking, arguing Decedent qualified as an individual Named Insured because the Amendment includes "their respective employees." PIIC argued Decedent was an insured (occupant/employee), not an individual Named Insured, so stacking is unavailable.
The trial court granted summary judgment for PIIC (finding UM coverage exhausted); the Court of Appeals (Western District) affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Decedent is an individual "Named Insured" under the Policy	Siddens: the Amendment’s phrase "and their respective employees" makes employees of the Named Insureds into Named Insureds, permitting stacking	PIIC: the Amendment adds employees as insureds (occupant insureds), but does not convert individual employees into the Named Insured (an organizational entity)	Court: Decedent is not a Named Insured; Amendment creates insureds (employees), not individual Named Insureds; no ambiguity
Whether PIIC’s reading renders policy language meaningless or contradictory (thus ambiguous)	Siddens: restricting stacking to "Named Insureds" is nonsensical because the Named Insureds are organizations that cannot suffer bodily injury, so policy should be read to allow employees to be Named Insureds and stack	PIIC: the policy differentiates Named Insureds (listed organizations) and insureds (employees); reading preserves meaning and is not ambiguous	Court: PIIC’s interpretation is consistent; policy terms are clear and not rendered meaningless; point irrelevant after holding Decedent is not a Named Insured

Warden v. Shelter Mut. Ins. Co., 480 S.W.3d 403 (Missouri Ct. App.) (insurance policy interpretation and de novo review)
Seeck v. Geico Gen. Ins. Co., 212 S.W.3d 129 (Mo. banc) (standard for construing insurance policy language)
Hall v. Allstate Ins. Co., 407 S.W.3d 603 (Mo. App.) (rules for policy ambiguity analysis)
Hines v. Gov’t Employees Ins. Co., 656 S.W.2d 262 (Mo. banc) (distinction between named insured and occupant/insured; stacking rules)
Linderer v. Royal Globe Ins. Co., 597 S.W.2d 656 (Mo. App.) (named insured vs. occupancy insured distinction)
Kertz v. State Farm Mut. Auto. Ins. Co., 236 S.W.3d 39 (Mo. App.) (limits clause applies to non-named insureds; stacking for named insureds)