Miecinski v. State Farm Mutual Automobile Insurance Co.

2024 IL App (1st) 230193 (Ill. App., 2024)

Words & Phrases

Underinsured Motorist Coverage: Stacking

Trial Judge

Alison C. Conlon

Appellate Judge

Reyes

Holding

Auto insurance policies unambiguously provided that UIM coverage limits could not be stacked.

Fact Summary

Kathryn Miecinski (Kathryn) was injured while riding on a motorcycle that was struck by
a vehicle. After settling for the $25,000 policy limit with the vehicle driver’s liability insurer, she sought additional underinsured motorist (UIM) benefits from three separate policies under which she was insured by State Farm Mutual Automobile Insurance Company (State Farm). As each policy included a $500,000 UIM coverage limit, Kathryn filed an action in the circuit court of Cook County, seeking coverage of up to $1.425 million, i.e., $475,000 (representing the $500,000 limit minus the $25,000 settlement) under each of the three policies. State Farm argued that the policies unambiguously provided that the UIM coverage limits may not be “stacked” (i.e., aggregated or combined), and thus her maximum recovery was $475,000. The circuit court granted summary judgment in favor of State Farm and denied Kathryn’s motion for judgment on the pleadings, and Kathryn filed this appeal. Affirmed.

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