STATE FARM v BALZAN, CV-24-0140-PR

Background

Connor Balzan and his family were insured under five State Farm automobile policies, including Connor’s Hyundai policy and four household policies paid with Russell and Kimberly’s community funds. 1
After Connor was injured in a 2019 accident, State Farm paid UIM limits under Connor’s Hyundai policy and one household policy, but refused to allow stacking of the remaining three household policies. 2
State Farm relied on an anti-stacking clause limiting coverage when multiple policies are purchased by “one insured” on different vehicles. 3
Connor argued the household policies were purchased by multiple insureds, not “one insured,” because Russell, Kimberly, and others contributed to or procured the policies. 4
The superior court granted State Farm summary judgment, and the court of appeals affirmed in part but held Russell and Kimberly were not “one insured” under the statute. 5
The Arizona Supreme Court granted review to interpret A.R.S. § 20-259.01(H) and determine who counts as the statutory purchaser for anti-stacking purposes. 6

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Who is “one insured” under § 20-259.01(H)? 7	State Farm: the named insured who procures coverage is the purchaser.	Connor: any contributor to premiums can be a purchaser.	“One insured” means the named insured purchaser who procured coverage. 8
Do jointly paying spouses become separate purchasers under community property law? 9	State Farm: community funds do not make both spouses separate purchasers.	Connor: community payments make both spouses purchasers.	No; community property does not alter the statutory purchaser analysis. 10
May State Farm stack the household policies under the anti-stacking clause? 11	State Farm: the parents jointly procured the policies, so only one source of coverage exists.	Connor: the clause does not apply because there were multiple insured purchasers.	Yes; State Farm properly limited recovery to one household-policy source. 12

Key Cases Cited

Franklin v. CSAA Gen. Ins. Co., 255 Ariz. 409 (Ariz. 2023) (anti-stacking permitted only with clear, unambiguous policy language; subsection (H) ambiguity analyzed 13)
In re Estate of Podgorski, 249 Ariz. 482 (Ariz. Ct. App. 2020) (summary judgment reviewed de novo; facts viewed favorably to nonmovant 14)
Ariz. Pub. Integrity All. v. Fontes, 250 Ariz. 58 (Ariz. 2020) (statutory interpretation reviewed de novo 15)
In re Drummond, 257 Ariz. 15 (Ariz. 2024) (statutes construed by plain meaning in broader statutory context 16)
Columbus Life Ins. Co. v. Wilmington Tr., N.A., 255 Ariz. 382 (Ariz. 2023) (statutes read in context, not isolation 17)
State v. Serrato, 259 Ariz. 493 (Ariz. 2025) (secondary interpretive methods used when statutory language is ambiguous 18)
State v. Luviano, 255 Ariz. 225 (Ariz. 2023) (ambiguity triggers secondary methods of statutory construction 19)
Am. Fam. Mut. Ins. Co. v. Sharp, 229 Ariz. 487 (Ariz. 2012) (§ 20-259.01 must be construed as a whole and concerns UM/UIM coverage 20)
Beaver v. Am. Fam. Mut. Ins. Co., 234 Ariz. 584 (Ariz. Ct. App. 2014) (named insured has statutory authority to accept or reject UM/UIM coverage 21)
Lawrence v. State Farm Mut. Auto. Ins. Co., 184 Ariz. 145 (Ariz. Ct. App. 1995) (statute does not contemplate separate coverage elections by resident relatives or passengers 22)
Taylor v. Travelers Indem. Co. of Am., 198 Ariz. 310 (Ariz. 2000) (UM/UIM statute is remedial and generally favors coverage 23)
Eng v. Stein, 123 Ariz. 343 (Ariz. 1979) (community property does not merge spouses into a single legal person 24)
Selby v. Savard, 134 Ariz. 222 (Ariz. 1982) (either spouse may manage and control community property and bind the marital community 25)
Lorenz-Auxier Fin. Grp., Inc. v. Bidewell, 160 Ariz. 218 (Ariz. Ct. App. 1989) (marriage does not erase spouses’ separate legal identities 26)
Hrudka v. Hrudka, 186 Ariz. 84 (Ariz. Ct. App. 1995) (community property principles concern ownership, not independent contractual authority 27)