Stickley v. State Farm Fire & Casualty Co., 431 Md. 347

Petitioner Stickley, a passenger in a car accident, sustained serious injuries while her husband died; they carried a motor vehicle liability policy with State Farm Auto and a personal liability umbrella policy with State Farm Fire & Casualty Co.
The umbrella policy contains a household exclusion denying bodily injury claims against a household member; Petitioner challenges its validity under § 19-504.1 of the Insurance Article.
§ 19-504.1 requires insurers to offer family-member liability coverage at the same amount as nonfamily-member coverage under private passenger motor vehicle liability policies when that liability coverage exceeds minimum statutory amounts.
Lower courts held the umbrella policy is not a private passenger motor vehicle liability insurance policy, thus § 19-504.1 does not apply to it, and the household exclusion remains valid.
The Maryland Supreme Court granted certiorari to determine whether an umbrella policy falls within § 19-504.1 and whether enforcing the household exclusion contravenes public policy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does § 19-504.1 apply to umbrella policies?	Stickley contends umbrella policies are private passenger motor vehicle liability insurance under the statute.	State Farm argues umbrella policies are not private passenger motor vehicle liability insurance and thus § 19-504.1 does not require equal family coverage.	Umbrella policy is not private passenger motor vehicle liability insurance; § 19-504.1 does not apply.
Is enforcing the household exclusion against public policy when § 19-504.1 does not apply?	Public policy supports voiding the exclusion to ensure family-member recovery beyond minimums.	Public policy favors upholding the household exclusion consistent with statutory framework for compulsory auto insurance; legislature did not abrogate it entirely.	Household exclusion remains valid and enforceable; no public policy violation.

Bowen v. City of Annapolis, 402 Md. 587 (Md. 2007) (statutory interpretation guiding plain meaning of language)
State Farm v. Nationwide, 307 Md. 631 (Md. 1986) (public policy considerations in household exclusions)
Stearman v. State Farm Mut. Auto. Ins. Co., 381 Md. 436 (Md. 2004) (public policy and interpretation of household exclusion)
Allstate Ins. Co. v. Hart, 327 Md. 526 (Md. 1992) (statutory basis for household exclusion invalidity when applicable)
Neale v. Wright, 322 Md. 8 (Md. 1991) (attachment of private passenger motor vehicle liability to automobiles, not individuals)