State Farm Mutual Automobile Insurance Company v. Kimberly S. Earl and the Estate of Jerry Earl, 2015 Ind. LEXIS 506

Jerry Earl suffered catastrophic injuries in a 2008 hit‑and‑run motorcycle/tractor‑trailer collision; the tortfeasor was never identified.
Jerry and his wife Kimberly sued State Farm under their uninsured/underinsured motorist (UM) policy; State Farm admitted liability and the jury trial was limited to damages.
The State Farm policy provided $250,000 per person / $500,000 per accident UM limits; the trial court admitted evidence of the $250,000 per‑person limit over State Farm’s objection.
The jury awarded $175,000 to Jerry’s estate and $75,000 to Kimberly (total $250,000, equal to the policy per‑person limit).
State Farm appealed, claiming admission of the coverage limit was irrelevant and prejudicial; the Court of Appeals reversed (divided panel) and this Court granted transfer.
The Indiana Supreme Court affirmed, holding the trial court did not abuse its discretion in admitting the coverage limit given the contract claim posture, relevance as background, and proper jury instructions limiting improper use.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of policy coverage limit at damages phase	Coverage limit is relevant background and part of the contractual dispute; jury may be informed	Coverage limit is irrelevant to actual damages and its admission unfairly prejudices insurer	Court: Trial court did not abuse discretion; coverage limit was marginally relevant as background to contract claim and probative value was not substantially outweighed by unfair prejudice
Whether evidence of a policy limit would improperly inflate damages	Jury was properly instructed and substantial evidence supported award; any mention of limit did not force award	Exact match of award to policy limit proves prejudice and confusion	Court: The award matching the limit does not establish prejudice given evidence and instructions; jurors likely followed instructions
Whether bright‑line rule should apply to admit or exclude limits	Admit limits in UM contract suits	Exclude limits as irrelevant to tort damages	Court: Declined bright‑line rules; left admissibility to trial court discretion under relevance and Rule 403 balancing
Whether other remedies (e.g., umbrella policy) affect admissibility	Not raised at trial; umbrella discovered post‑verdict	Insurer argued jury might have been influenced by limits vs other coverage	Court: Did not decide umbrella issue; narrowly addressed only admission of $250,000 limit admitted at trial

TRW Vehicle Safety Sys., Inc. v. Moore, 936 N.E.2d 201 (Ind. 2010) (standard of review for evidentiary rulings—abuse of discretion)
Santelli v. Rahmatullah, 993 N.E.2d 167 (Ind. 2013) (abuse of discretion defined)
Malott v. State Farm Mut. Auto. Ins. Co., 798 N.E.2d 924 (Ind. Ct. App. 2003) (permitting jury instruction about policy limits in UM contract suits)
Allstate Ins. Co. v. Hammond, 759 N.E.2d 1162 (Ind. Ct. App. 2001) (UM claim treated as contract action where limits may be relevant)
Allstate Ins. Co. v. Hennings, 827 N.E.2d 1244 (Ind. Ct. App. 2005) (discussing jury instructions and policy limits in UM cases)
Brown-Day v. Allstate Ins. Co., 915 N.E.2d 548 (Ind. Ct. App. 2009) (real party in interest insurer makes evidence of insurance permissible)
Morse v. Davis, 965 N.E.2d 148 (Ind. Ct. App. 2012) (reversal standard when inadmissible evidence is placed before jury)
Bob Schwartz Ford, Inc. v. Dunham, 631 N.E.2d 953 (Ind. Ct. App. 1994) (upholding comparable damages awards for severe permanent injuries)