State Farm Mut. Ins. Co. v. Hodgkiss-Warrick
Annotate this CasePlaintiff was a Pennsylvania resident who was injured in Kentucky. Plaintiff's daughter, with whom Plaintiff resided, was driving the vehicle involved in the accident. Plaintiff brought suit against her insurance carrier, State Farm Mutual Automobile Insurance Company, for underinsured motorist (UIM) coverage under a policy issued in Pennsylvania and covering a vehicle that Plaintiff registered and used exclusively in Pennsylvania. The trial court and court of appeals concluded that Pennsylvania law governed the dispute between Plaintiff and State Farm, but the two courts reached different results. The trial court concluded that Plaintiff was not entitled to UIM coverage because her policy disallowed coverage when she was injured in an underinsured vehicle owned or regularly used by a "resident relative." The court of appeals found Kentucky public policy would prohibit enforcement of the policy provision and concluded Plaintiff was entitled to UIM coverage despite the plain language of her policy. The Supreme Court reversed, holding (1) Pennsylvania law applied to this dispute; and (2) there was no prohibition on the type of UIM exclusion at issue in this case.
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