Landrum v. Infinity Safeguard Insurance, 318 Ga. App. 701

Landrum (named insured) was injured as a passenger when her grandson Turner, driving Landrum's car, ran a stop sign and collided with a third party.
Turner resided with Landrum and had no auto liability policy other than the Infinity policy at issue.
Landrum filed suit for personal injuries against Turner; Infinity filed a declaratory judgment seeking coverage interpretation.
The policy covers bodily injury up to $25,000 per person and $50,000 per accident, with an exclusion for bodily injury to 'you' (the named insured).
Insured includes you, a relative or resident, or a person using the insured auto with permission; a relative must be listed on the application or endorsed prior to loss.
Turner was not listed as a relative on the policy; the trial court granted Infinity summary judgment finding no coverage for Turner and no UM coverage for Landrum.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the bodily injury exclusion for a named insured violates public policy.	Landrum argues the exclusion leaves an innocent victim/unanticipated liability.	Infinity contends exclusions are valid unless Congress or Georgia law requires coverage; Turner is a permissive driver, not insured.	Exclusion upheld; not void as against public policy for these facts.
Whether Turner, as a permissive driver not listed as an insured, faces unfair exposure to liability warranting voiding the exclusion.	Landrum/Turner rely on public policy to protect an innocent victim or insured from unanticipated liability.	Turner is a permissive driver with no listed interest; policy treats him as non-insured.	Turner does not face unfair exposure; exclusion remains valid.

Southern Guaranty Ins. Co. v. Preferred Risk Mut. Ins. Co., 257 Ga. 355 (Ga. 1987) (public policy limits on exclusions; innocent victim/insured protection analysis)
Stepho v. Allstate Ins. Co., 259 Ga. 475 (Ga. 1989) (intrafat family immunity and protection of insureds informed by policy)
Chaney v. Southeastern Fidelity Ins. Co., 259 Ga. 474 (Ga. 1989) (named insured exclusion challenged when reliance on intrafamily liability does not apply)
Spivey v. Safeway Ins. Co., 210 Ga. App. 775 (Ga. App. 1993) (bright-line rule against voiding exclusions for permissive drivers; stare decisis relevance)
Cotton States Mut. Ins. Co. v. Coleman, 242 Ga. App. 531 (Ga. App. 2000) (continuation of permissive-driver exclusion under public policy)
Smith v. Nationwide Mut. Ins. Co., 258 Ga. App. 570 (Ga. App. 2002) (affirmation of exclusion for permissive drivers when not residing with insured)
Federated Mut. Ins. Co. v. Dunton, 213 Ga. App. 148 (Ga. App. 1994) (emphasizes public policy considerations in exclusions under mandatory statute context)
Stout v. Cincinnati Ins. Co., 269 Ga. 611 (Ga. 1998) (stare decisis; predictability in application of public policy principles)