Williams v. Geico Government Employees Insurance
32 A.3d 1195
Pa.2011Background
- Williams, a Pennsylvania State Police Trooper since 1994, was seriously injured on June 23, 2004 while driving a state vehicle.
- He had a GEICO personal auto policy with UIM coverage; GEICO denied UIM benefits due to a regular-use exclusion for a vehicle furnished for regular use.
- GEICO moved for summary judgment in a combined declaratory judgment/arbitration action; the trial court granted summary judgment denying UIM benefits.
- The Superior Court affirmed, relying on Brink v. Erie Ins. Group to hold the regular-use exclusion valid against a police officer in the line of duty.
- The Supreme Court granted review to determine if public policy requires extending UIM coverage to first responders despite the regular-use exclusion.
- Court analyzed MVFRL and public policy, reaffirming Burstein and holding the regular-use exclusion is not void as against public policy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the regular-use exclusion void UIM coverage for a police officer in the line of duty? | Williams argues public policy protects first responders, demanding UIM despite the exclusion. | GEICO contends the exclusion is valid and consistent with MVFRL cost-containment goals; Burstein controls. | Regular-use exclusion not void; affirmed. |
| Do statutory provisions for first responders (Heart and Lung Act, Workers' Comp, etc.) create a public policy requiring UIM coverage for first responders in private policies? | Public policy statutes show broader protections for first responders necessitating coverage. | Statutes are narrower and do not preclude the long-standing exclusions in MVFRL; legislative prerogative. | No unanimity; exclusion remains valid. |
| Does the MVFRL require waivers under 75 Pa.C.S. § 1731 to preclude application of the regular-use exclusion? | Written waivers required; exclusion improperly voids statutorily mandated coverage. | MVFRL stacking provisions do not preclude regular-use exclusions; Burstein intact. | Waiver provisions do not render the exclusion invalid. |
Key Cases Cited
- Burstein v. Prudential Prop. & Cas. Ins. Co., 570 Pa. 177 (2002) (regular-use exclusion upheld; cost containment policy)
- Eichelman v. Nationwide Ins. Co., 551 Pa. 558 (1998) (public policy limits on interpreting contracts; plain meaning unless policy exists)
- Generette v. Donegal Mut. Ins. Co., 598 Pa. 505 (2008) (public policy balancing; deference to legislatures)
- Brink v. Erie Ins. Group, 940 A.2d 528 (Pa. Super. 2008) (distinguishes Burstein; regular-use exclusion applied to police in some contexts)
- Erie Ins. Exchange v. Baker, 601 Pa. 355 (2009) (MVFRL stacking; household exclusion contexts; public policy limits)
- Colbert v. Columbia Casualty Co., 813 A.2d 747 (2002) (public policy scope and contractual interpretation under MVFRL)