Owned-Vehicle Exclusion Upheld to Limit Coverage to MVFRL Minimum

Missouri’s Eastern District Court of Appeals recently upheld an owned-vehicle exclusion limiting Uninsured Motorist Coverage to the statutory minimum for non-occupied vehicles. The insured argued that she was entitled to the full per-person limits under policies insuring three owned vehicles, including two that were not involved in injury-causing occurrence, because the policies were ambiguous as to whether stacking was permitted and violated Missouri public policy. The policies limited coverage for vehicles owned by the insured, but not occupied or involved in the occurrence to Missouri’s statutory minimum of $25,000. The Eastern District confirmed that the exclusionary language unambiguously limited the insured’s recovery under the policies insuring the two unoccupied vehicles to the $25,000 minimum required by Missouri’s Motor Vehicle Financial Responsibility Law. This decision is further confirmation by Missouri courts that public policy considerations are limited to the MVFRL requirements and UM coverage can be limited by clear, unambiguous policy language. See Purk v. Farmers Ins. Co., Inc., No. ED 109191, 2021 WL 2096376 (Mo. Ct. App. May 25, 2021).