Wood v. Farmers Insurance Co of IdahoAnnotate this Case
Deena Wood was seriously injured in a car collision. At the time of the collision, Wood had auto insurance through Farmers Insurance Company of Idaho, which included $100,000 of underinsured motorist ("UIM") coverage but also contained a provision stating that the amount of coverage would be reduced by the liability limit of the at-fault driver. Because the at-fault driver’s bodily injury liability limit was equal to Wood’s underinsured motorist limit, Farmers determined that no underinsured benefits were owed to Wood. Wood challenged the denial in district court, arguing in a motion for reconsideration that the offset provision should be declared void as against public policy because it “diluted” UIM coverage. The district court rejected Wood’s argument. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s decision.