744 F.3d 582
8th Cir.2014Background
- Crain and wife were northbound in a 1998 Ford Taurus when a southbound vehicle turned in front of them, causing a collision; Crain was seriously injured and his wife died.
- After settling with the other vehicle's owner/driver for policy limits, Crain, individually and on behalf of his wrongful death class, sought UIM benefits from State Farm under both of the Crains' policies.
- State Farm paid UIM benefits under the Taurus policy but denied UIM under a separate Pontiac Catalina policy (1979) that was not involved in the accident, due to an anti-stacking provision.
- Crain filed suit in Missouri state court on January 27, 2012 seeking UIM benefits under the Pontiac policy; the case was removed to the Western District of Missouri on diversity grounds.
- The district court granted summary judgment for State Farm, holding the Pontiac policy unambiguously precluded stacking; Crain appealed arguing Missouri law construing ambiguities in the insured's favor and policy terms support stacking under the Pontiac policy.
- The panel reaffirmed binding precedent that the policy unambiguously precludes stacking and affirmed the district court’s ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether UIM stacking is permissible under Missouri law. | Crain asserts stacking should be allowed under policy terms and Missouri law. | State Farm argues the Pontiac policy unambiguously precludes stacking. | Stacking precluded; no reversal. |
| Whether Missouri law construing ambiguities in favor of insured applies. | Crain contends ambiguities should favor insureds. | State Farm relies on unambiguous policy language. | Ambiguities do not change outcome; policy unambiguous. |
| Whether the district court properly granted summary judgment on the policy language. | Crain argues genuine issues of material fact exist regarding policy interpretation. | Policy language unambiguously precludes stacking, no fact issue. | Affirmed summary judgment. |
Key Cases Cited
- Ritchie v. Allied Prop. & Cas. Ins. Co., 307 S.W.3d 132 (Mo. 2009) (en banc definition of stacking cited by court with Missouri law framework)
- Mader v. United States, 654 F.3d 794 (8th Cir. 2011) (one panel bound by prior panel decision)
- Niswonger v. Farm Bureau Town & Country Ins. Co. of Mo., 992 S.W.2d 308 (Mo. Ct. App. 1999) (definition and limits of stacking in Missouri)