Dooley v. Hartford Accident & Indemnity Co., No. 12-1882 (4th Cir. 2013)
Annotate this CasePlaintiff, the insured, appealed the district court's holding that his Hartford insurance policy prohibited plaintiff from "stacking," or combining the uninsured/underinsured motorist coverage (UM/UIM) for each insured vehicle, when the policy failed to specify any particular amount of UM/UIM coverage afforded. The court concluded that because Virginia Code 38.2-2206(A) mandated that UM/UIM coverage "shall equal" the general liability coverage, this provision by operation of law provided plaintiff an equal amount of UM/UIM coverage under the Hartford policy. Accordingly, the court held that the anti-stacking provision in plaintiff's policy unambiguously prevented the stacking of UM/UIM coverage, and affirmed the district court's award of summary judgment in favor of Hartford.
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