State Farm Mutual Automobile Insurance v. White, 231 Ariz. 337

White appeals after the superior court denied underinsured motorist (UIM) benefits for her son's wrongful death under a State Farm policy purchased by the grandparents.
State Farm concedes the policy would cover the wrongful death but argues § 20-259.03 bars recovery.
Facts: White's son died in a head-on collision involving an underinsured driver; the son was a passenger in a rental car driven by his maternal grandmother, Carol.
Policy provides UIM coverage of $250,000 per person/$500,000 per accident; insured includes occupants and those entitled to recover damages because of bodily injury to an insured.
White did not reside primarily with Carol and John and was not a relative under the policy; the superior court granted summary judgment for State Farm.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 20-259.03 bars UIM recovery to White	White is a surviving insured under the policy	White is not a surviving insured under the policy	§ 20-259.03 does not bar payment to a surviving insured.

Bither v. Country Mut. Ins. Co., 226 Ariz. 198, 245 P.3d 883 (Ariz. Ct. App. 2010) (statutory beneficiary not insured; § 20-259.03 applies to surviving insured status)
McKeon, Employers Mut. Cas. Co. v. McKeon, 159 Ariz. 111, 765 P.2d 513 (Ariz. 1988) (UIM coverage extends to the amount elected by the named insured; not a minimum-only rule)
Walsh v. Advanced Cardiac Specialists Chartered, 229 Ariz. 193, 273 P.3d 645 (Ariz. 2012) (wrongful-death damages; broad discretion in compensation under § 12-612)
Estate of Bhatt v. State, State v. Bhatt, 227 Ariz. 523, 260 P.3d 1088 (Ariz. App. 2011) (statutory interpretation; plain-language approach)
City of Tempe v. Fleming, 168 Ariz. 454, 815 P.2d 1 (Ariz. Ct. App. 1991) (do not read words in isolation; give statute their plain meaning)
Deer Valley Unified Sch. Dist. No. 97 v. Houser, 214 Ariz. 293, 152 P.3d 490 (Ariz. 2007) (statutory interpretation principle: plain meaning governs)