This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The case arose from a motor vehicle accident on July 19, 2001, resulting in the death of the Plaintiff's wife. The Plaintiff, acting individually and as the personal representative of his wife’s estate, sought a declaratory judgment against his insurer, MetLife Auto & Home Insurance Co., regarding whether the uninsured/underinsured motorist coverage under the policy was stackable. The Plaintiff had previously settled claims against other defendants involved in the accident.
Procedural History
- District Court, Lincoln County, Karen L. Parsons, District Judge: Granted summary judgment in favor of the Plaintiff, concluding that the uninsured/underinsured motorist coverage under the MetLife policy was stackable.
Parties' Submissions
- Appellant (MetLife Auto & Home Insurance Co.): Argued that the district court erred in concluding that the uninsured/underinsured motorist coverage was stackable. MetLife contended that the policy’s anti-stacking provisions were unambiguous and complied with the requirements set forth in prior case law, specifically Rodriguez v. Windsor Insurance Co..
- Appellee (Plaintiff): Asserted that the district court’s decision was correct and that the policy was ambiguous, warranting stacking. The Plaintiff also argued that certain provisions of the policy implied stacking and that the insurer failed to meet statutory and regulatory requirements for rejecting stacking.
Legal Issues
- Was the district court’s summary judgment order a final, appealable order?
- Did the district court err in concluding that the uninsured/underinsured motorist coverage under the MetLife policy was stackable?
- Was the MetLife policy ambiguous in a manner that required stacking of uninsured/underinsured motorist coverage?
Disposition
- The Court of Appeals reversed the district court’s summary judgment, holding that the uninsured/underinsured motorist coverage under the MetLife policy was not stackable.
Reasons
Per Sutin CJ (Wechsler and Bustamante JJ. concurring):
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The Court first addressed the issue of finality and concluded that the district court’s order was a final, appealable order. The Plaintiff’s claims against other defendants had been resolved, and the declaratory judgment against MetLife did not involve damages, leaving no outstanding issues.
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The Court determined that the rule announced in Montano v. Allstate Indemnity Co., which required a written waiver of stacking, did not apply retroactively to this case because the injuries occurred before Montano was decided. Instead, the case was governed by the precedent in Rodriguez v. Windsor Insurance Co..
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Applying Rodriguez, the Court found that the anti-stacking provisions in the MetLife policy were unambiguous. The policy clearly stated that uninsured/underinsured motorist coverage was provided on a per-policy basis, regardless of the number of vehicles insured. The declarations page and endorsement AUTO2859 explicitly notified the insured that only one premium was charged for the coverage and that stacking was not permitted.
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The Court rejected the Plaintiff’s arguments regarding ambiguity. It held that any alleged ambiguities in the policy did not pertain to stacking but rather to other aspects of coverage, such as the limits applicable to specific vehicles. These ambiguities, if present, did not undermine the clear anti-stacking provisions.
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The Court concluded that the district court erred in finding the policy ambiguous and in allowing stacking of uninsured/underinsured motorist coverage.