Christopher Wallace v. Grange Insurance Company, No. 2021-CA-0715. Mr. Wallace sought Uninsured Motorist (“UM”) benefits under a policy of insurance issued to his employer. He argued that because Grange was unable to locate a signed rejection of UM coverage, Grange owed UM coverage up to the liability limits, which were $1 million. Furthermore, because there were two vehicles listed on the policy, Mr. Wallace argued the UM coverage should stack, resulting in a total of $2 million in available UM limits. On behalf of Grange, Elizabeth argued that pursuant to statutory authority and case law, the UM limits owed were the minimum liability limits established by the Kentucky Motor Vehicle Reparations Act, $25,000 per person/$50,000 per accident, and that the UM limits did not stack both because Mr. Wallace was a second-class insured and because separate premiums had not been paid for UM coverage for the two vehicles listed on the policy (in fact, no premiums for UM coverage had been paid). Both the Warren Circuit Court and the Kentucky Court of Appeals agreed with Elizabeth, and it was ultimately held that Mr. Wallace was entitled to only $25,000 in UM coverage.
