Background
Zachary Beaver was injured by an uninsured driver while performing asphalt work in a closed construction-zone roadway. His employer’s workers’ compensation insurer had paid more than $500,000 for his medical care. Beaver and his wife, Angie, also sought damages for Angie Beaver’s loss of consortium.
The Beavers’ American Family policy covered two vehicles and listed uninsured-motorist bodily-injury limits of $250,000 per vehicle and $500,000 per accident. American Family reduced the first vehicle’s UM limit to $25,000 based on workers’ compensation payments, and reduced the second vehicle’s stacked coverage to Missouri’s $25,000 minimum under the policy’s anti-stacking and step-down language. It paid $50,000 total. The circuit court granted summary judgment to American Family.
The Court’s Holding
The court held that the workers’ compensation reduction clause was unambiguous but void as against public policy. Missouri insurance regulation 20 CSR 500-2.100(2)(G)(1) prohibits UM coverage provisions that permit workers’ compensation setoffs, and the court read that prohibition to apply to UM coverage above the statutory minimum as well as to minimum coverage.
The court upheld the provision limiting legally required stacked UM coverage on the second vehicle to $25,000. Although Missouri law invalidates the policy’s general ban on stacking, the court held that the separate step-down provision was unambiguous and valid because it preserved the mandatory minimum UM coverage for the stacked vehicle. The court affirmed in part and reversed in part, directing entry of judgment for the Beavers for $225,000 after crediting the $50,000 already paid.
Key Takeaways
- An insurer may not reduce UM benefits by workers’ compensation payments, including UM coverage purchased above Missouri’s statutory minimum.
- A general anti-stacking clause is unenforceable under Missouri law, but a policy may limit required stacked UM coverage to $25,000 per vehicle.
- The Beavers were entitled to $250,000 for the first vehicle and $25,000 for the second, less the $50,000 American Family had paid.
Why It Matters
The decision treats Missouri’s regulatory prohibition on workers’ compensation setoffs as applying to all UM coverage offered in an automobile policy, not merely the coverage required by statute. Insurers cannot use workers’ compensation payments to eliminate optional UM limits for which insureds paid premiums.
At the same time, the opinion confirms that Missouri insurers may use clear policy language to cap stacked UM coverage at the statutory minimum, even when the policy’s individual vehicle limits are higher.