Wilbur v. State Farm Mutual Automobile Insurance Co., 892 N.W.2d 521

On Jan. 10, 2009, John Wilbur was injured in a rear-end collision; the at-fault insurer paid its $100,000 policy limit. Wilbur’s UM/UIM policy with State Farm also had a $100,000 limit.
Wilbur demanded the $100,000 UIM limit; State Farm initially paid $1,200 and later offered an additional $26,800, which Wilbur rejected.
Wilbur sued for breach of contract; a jury awarded $412,764.63 in damages, later reduced to $255,956.59 after credits. District court entered judgment for $98,800 (policy limit minus the $1,200 payment).
Wilbur then prevailed in a separate trial under Minn. Stat. § 604.18, which permits awarding “taxable costs” (one-half of the “proceeds awarded” in excess of a pretrial offer or $250,000, whichever is less) when an insurer unreasonably denies benefits.
The key dispute: whether “proceeds awarded” in § 604.18 is capped by the insured’s policy limit (which would yield a much smaller § 604.18 award) or whether it refers to the full judgment amount not restricted by the policy limit.
District court held the phrase is capped by the policy limit and awarded Wilbur $36,000 under § 604.18; the court of appeals affirmed. The Minnesota Supreme Court affirmed, holding the statute unambiguously caps proceeds by the policy limit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether “proceeds awarded” in Minn. Stat. § 604.18, subd. 3(a)(1), is capped by the insurance policy limit	Wilbur: “Proceeds awarded” means the amount the factfinder awards (the judgment amount) and is not limited by the policy cap	State Farm: “Proceeds awarded” refers to insurance-policy proceeds and is limited by the policy limit; § 604.18 contemplates capped insurer offers	Court: Held unambiguously that “proceeds awarded” are capped by the insurance policy limit

Boutin v. LaFleur, 591 N.W.2d 711 (Minn. 1999) (statutory interpretation reviewed de novo)
Amaral v. St. Cloud Hosp., 598 N.W.2d 379 (Minn. 1999) (statute ambiguous only if more than one reasonable interpretation exists)
Am. Family Ins. Group v. Schroedl, 616 N.W.2d 273 (Minn. 2000) (read statute as whole; examine surrounding sections)
State v. Maurstad, 733 N.W.2d 141 (Minn. 2007) (purpose of statutory interpretation is to effectuate legislative intent)
State v. Struzyk, 869 N.W.2d 280 (Minn. 2015) (canons of construction applied only when statute is ambiguous)
Clark v. Pawlenty, 755 N.W.2d 293 (Minn. 2008) (same word in same statute should have consistent meaning)
Akers v. Akers, 46 N.W.2d 87 (Minn. 1951) (words in different subdivisions of same statute must be given same meaning)
KSTP-TV v. Metro. Council, 884 N.W.2d 342 (Minn. 2016) (courts interpret statutes as written; legislative change for policy concerns)
Latterell v. Progressive N. Ins. Co., 801 N.W.2d 917 (Minn. 2011) (distinguishing first-party and third-party claims)
In re Welfare of J.B., 782 N.W.2d 535 (Minn. 2010) (legislative history generally consulted only when statute is ambiguous)