Leslie Seaton v. Shelter Mutual Insurance Company, 574 S.W.3d 245

Chelsea Seaton (decedent) died as a passenger in a vehicle driven by Megan Deaton; Deaton settled a wrongful-death claim for her policy limits.
Leslie Seaton sought underinsured motorist (UIM) benefits from three automobile policies she held with Shelter Mutual Insurance Company.
Shelter paid UIM under one policy but denied coverage under the other two, asserting the decedent was not an “insured” under those policies.
Seaton sued for a declaratory judgment and breach of contract; the circuit court granted summary judgment for Seaton; Shelter appealed; the Supreme Court of Missouri granted transfer.
The dispositive legal question was whether the decedent fit any of the policy definitions of an “insured” entitled to UIM benefits and whether the policies were internally inconsistent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether decedent was an “insured” under the UIM endorsements	Seaton: decedent (daughter) is a relative and thus an insured; policy language ambiguous and should be construed in favor of coverage	Shelter: policy unambiguously limits insureds to (a) “you” (named insured), (b) “relative” who does not own a vehicle, or (c) certain additional listed insureds who do not own a vehicle; decedent owned a vehicle and was not a named insured	Court: Decedent was not an insured. She was not a named insured, was listed as a title owner of a vehicle (so excluded from the “relative” definition), and was not occupying a described auto insured by Shelter at the time of the accident.
Whether the policies are internally inconsistent/ambiguous such that exclusion should be disregarded	Seaton: alleged internal inconsistency between provisions promising coverage and later provisions denying it, creating ambiguity	Shelter: policies consistently limit UIM to defined insureds; no ambiguity when applied as written	Court: No need to resolve alleged internal inconsistency because decedent is not an insured; policies are not rendered ambiguous merely because they limit coverage to insureds.

ITT Commercial Fin. Corp. v. Mid-Am. Marine Supply Corp., 854 S.W.2d 371 (Mo. banc 1993) (standard for de novo appellate review of summary judgment)
Owners Ins. Co. v. Craig, 514 S.W.3d 614 (Mo. banc 2017) (insurance-policy interpretation is a question of law reviewed de novo)
Seeck v. Geico Gen. Ins. Co., 212 S.W.3d 129 (Mo. banc 2007) (plain-meaning approach to policy language)
Doe Run Res. Corp. v. Am. Guar. & Liab. Ins., 531 S.W.3d 508 (Mo. banc 2017) (give policy language its plain meaning)
Piatt v. Ind. Lumbermen’s Mut. Ins. Co., 461 S.W.3d 788 (Mo. banc 2015) (definitions, exclusions, conditions, and endorsements are necessary provisions)
Taylor v. Bar Plan Mut. Ins. Co., 457 S.W.3d 340 (Mo. banc 2015) (enforce clear policy language as written)
Maxam v. Am. Family Mut. Ins. Co., 504 S.W.3d 124 (Mo. App. W.D. 2016) (presence of an exclusion does not by itself create ambiguity)
Lair v. Am. Family Mut. Ins. Co., 789 S.W.2d 30 (Mo. banc 1990) (relative excluded from UM/UIM coverage where policy excluded relatives who own a car)
Swadley v. Shelter Mut. Ins. Co., 513 S.W.3d 355 (Mo. banc 2017) (policy limits to insured persons do not by themselves create ambiguity)
Carter v. Shelter Mut. Ins. Co., 516 S.W.3d 370 (Mo. App. E.D. 2017) (interpreting Shelter policy language regarding named and additional listed insureds)