Staufenbiel v. Amica Mutual Insurance Company
4:13-cv-02571
| E.D. Mo. | Mar 30, 2015Background
- On Feb. 23, 2013 Jonathan Staufenbiel was struck by a vehicle; the tortfeasor's insurer paid the $100,000 policy limit.
- Staufenbiel was an additional insured on his parents’ Amica policy, which listed UIM limits of $100,000 per person per vehicle (four vehicles; $100k each) and $300,000 per accident.
- Plaintiff demanded $400,000 (stacking the four $100k vehicle limits); Amica refused, citing anti-stacking and duplicate-payment provisions and other policy conditions.
- Plaintiff sued for breach of contract (Count I) and vexatious refusal/bad faith (Count II); Amica moved for summary judgment.
- The court found (1) the policy unambiguously prohibits stacking, (2) the policy disallows duplicate recovery of elements already paid by the tortfeasor (so claimant may recover only damages in excess of the $100k received), and (3) disputed factual issues remain about whether plaintiff breached cooperation/legal-action clauses.
- The court granted summary judgment in part: dismissed Count II (vexatious refusal) with prejudice but left Count I (breach) survivable to the extent plaintiff could show damages exceeding $100,000 and unresolved cooperation issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Stacking of UIM limits | Staufenbiel contends policy language (insuring grant + declarations) permits stacking the four $100k vehicle limits (total $400k). | Amica argues the Limit of Liability clause unambiguously prohibits stacking; the policy caps liability per person at $100k regardless of number of vehicles. | Court: Anti-stacking language is unambiguous; stacking prohibited; applicable limit $100,000. |
| Offset / Duplicate recovery | Plaintiff argues "duplicate payment" language is ambiguous and does not allow offsetting tortfeasor recovery against UIM. | Amica contends Subpart C prohibits duplicate payment for elements already paid by tortfeasor, effectively reducing recoverable UIM to damages in excess of amounts already received. | Court: Provision prohibits duplicate recovery; UIM applies only to damages exceeding the $100k already received. |
| Cooperation & legal-action clauses | Staufenbiel says he cooperated (produced records, attempted to schedule exam under oath) and any noncompliance was not prejudicial. | Amica contends plaintiff failed to submit to examination under oath and provide complete documentation, prejudicing coverage and violating policy preconditions. | Court: Material factual dispute exists whether plaintiff materially breached cooperation; therefore coverage denial on that ground is not decided at summary judgment. |
| Vexatious refusal (bad faith) | Plaintiff contends Amica acted without reasonable cause in denying UIM stacking and refusing payment. | Amica says its refusal was reasonable because plaintiff demanded $400k despite unambiguous $100k limit and no pre-suit demand within policy limit. | Court: No vexatious refusal as a matter of law; dismissal of Count II with prejudice because no pre-suit demand within $100k and insurer had a reasonable basis to deny $400k demand. |
Key Cases Cited
- Ritchie v. Allies Property & Cas. Ins. Co., 307 S.W.3d 132 (Mo. 2007) (explains stacking and duplicate-recovery principles under Missouri law)
- Seeck v. Geico Gen. Ins. Co., 212 S.W.3d 129 (Mo. 2007) (policy ambiguity construed against insurer; anti-stacking enforceability depends on clarity)
- Rodriguez v. Gen. Acc. Ins. Co. of Am., 808 S.W.2d 379 (Mo. 1991) (UIM stacking determined by contract terms when coverage is optional)
- Med. Protective Co. v. Bubenik, 594 F.3d 1047 (8th Cir. 2010) (elements required to deny coverage for breach of cooperation clause)
- Chamness v. American Family Mut. Ins. Co., 226 S.W.3d 199 (Mo. Ct. App. 2007) (example where conflicting clauses created ambiguity allowing stacking)