Broderick v. Dairyland Insurance Co., 270 P.3d 684

Appellant injured in motorcycle accident with underinsured motorist claim arising from Dairyland policy procured through Schrack.
Policy lacked underinsured motorist coverage; policy defined uninsured motorist but not underinsured.
Appellant settled with other driver's insurance for $25,000; policy limits were $100,000 per person/$300,000 per accident.
Appellant sought $75,000 from Dairyland after settlement to reach policy limits; Dairyland and Schrack moved for summary judgment.
District court ruled there was no ambiguity in statutes or contract to require underinsured coverage and rejected reform/estoppel/extra-contractual theories; this appeal followed.
Court affirmed summary judgments, holding statutes do not require underinsured coverage and the policy unambiguously omitted it.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court properly granted summary judgment	Appellant argues UIM coverage should be implied	Dairyland/Schrack contend statutes and policy unambiguously omit UIM	Yes, district court affirmed (summary judgment upheld)

Hamilton v. Dairyland, 2010 WY 57 (Wy. 2010) (central to mutual mistake and agency authority standards)
Ohio Casualty Ins. Co. v. Jones, 2010 WY 57 (Wy. 2010) (agency authority limits to bind insurer; enforce policy terms)
St. Paul Fire & Marine Ins. Co. v. Albany County Sch. Dist. No. 1, 763 P.2d 1255 (Wy. 1988) (reasonable expectations doctrine boundaries when unambiguous)
Aaron v. State Farm Mut. Auto. Ins. Co., 2001 WY 112 (Wy. 2001) (Wyoming silent on underinsured coverage; no obligation to read into policy)
Harper v. Fid. & Guar. Life Ins. Co., 2010 WY 89 (Wy. 2010) (promissory estoppel requires clear, definite promise; reliance must be reasonable)