Hall v. Allstate Insurance Co.
407 S.W.3d 603
| Mo. Ct. App. | 2012Background
- Allstate appeals a trial court ruling that allowed stacking of underinsured motorist (UIM) benefits under the Hall policy.
- The Halls (Brian and Alyson Hall) sustained damages from an accident caused by Lorraine Guth; Guth’s policy limits were exhausted.
- The Hall policy insured three vehicles with UIM coverage of $50,000 per person and $100,000 per accident, with separate premiums for each vehicle.
- The Halls sought to stack the UIM benefits to total $150,000, arguing either express stacking language or ambiguity via the “other insurance” provision.
- The trial court granted summary judgment for stacking; Allstate appealed on grounds that the policy unambiguously forbids stacking.
- The court reviews a summary-judgment ruling de novo and interprets the insurance policy language as a whole to determine ambiguity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the policy unambiguously bars UIM stacking. | Hall argues policy allows stacking via declarations and limits clause. | Allstate asserts policy explicitly prohibits stacking. | Anti-stacking language unambiguous; stacking not permitted. |
| Whether the “other insurance” provision creates an ambiguity that would permit stacking. | Halls rely on excess/other-insurance language to support stacking. | Policy language distinguishes this case from Ritchie; no ambiguity. | No ambiguity; policy interpreted as written and stacking denied. |
| Whether Mrs. Hall’s loss-of-consortium UIM benefits are recoverable. | Halls contend entitlement to consortium UIM benefits. | Allstate opposes recovery of consortium benefits. | Affirm ruling denying consortium benefits; stacking reversal unaffected. |
Key Cases Cited
- Niswonger v. Farm Bureau Town & Country Ins. Co. of Missouri, 992 S.W.2d 308 (Mo.App.E.D.1999) (uninsured/multipolicy stacking context; policy interpretation guidance)
- Ritchie v. Allied Property & Cas. Ins. Co., 307 S.W.3d 132 (Mo. banc 2009) (ambiguity doctrine when anti-stacking vs. excess language conflicts in multiple policies)
- Rodriguez v. Gen. Acc. Ins. Co. of Am., 808 S.W.2d 379 (Mo. banc 1991) (public policy on stacking under uninsured vs underinsured; selection of contract terms)
- Long v. Shelter Ins. Companies, 351 S.W.3d 692 (Mo.App. W.D.2011) (anti-stacking clause enforceable when language clear)
- Krombach v. Mayflower Ins. Co., Ltd., 827 S.W.2d 208 (Mo. banc 1992) (ambiguity rules apply to insurance contracts)