Brethren Mut. Ins. Co. v. BuckleyAnnotate this Case
Ember Buckley was a passenger in a motor vehicle driven by Harvey Betts when the vehicle was involved in an accident. Buckley, who sustained injuries in the accident, settled with GEICO, Betts’ insurer, for the full policy limits and signed a full release of all claims against Betts and a hold harmless agreement in favor of GEICO. Buckley then attempted to recover for the remainder of her outstanding medical bills under her uninsured/underinsured motorist (“UM”) policy with The Brethren Mutual Insurance Company (“Brethren”), which denied coverage. Buckley filed suit, alleging breach of contract and seeking the policy limit in compensatory damages. The circuit court entered summary judgment for Brethren, concluding that the release was a general release, and thus released all entities from future claims, regardless of whether they were a party to the release. The court of special appeals reversed, holding that the general release did not prejudice Buckley’s claim against Brethren. The Court of Appeals affirmed, holding (1) the broad, all-inclusive language of the release must be read with an eye toward the parties’ overall intent; and (2) that the court of special appeals correctly held that the release did not waive Buckley’s UM claim against Brethren.