Current Issues in Underinsured and Uninsured Insurance Coverage in Missouri
Uninsured Motor Vehicle Coverage – Uninsured Status
Barring legislative amendments to the statute, the requirement in Cameron to stack uninsured motorist coverage is unlikely to change. As UM is statutorily required, insurers must allow insureds to stack each policy up to the statutorily required minimums even when the policies are issued by the same insurance carrier or take the form of a combined policy listing multiple automobiles. Blumer v. Auto. Club Inter-Ins. Exchange, 340 S.W.3d 214, 220 (Mo. App. W.D. 2011) (allowing the insured to stack the $25,000 statutory minimum from two uninsured policies for a $50,000 recovery, but not requiring stacking of the full coverage limit contained in each policy). Cases on other topics occasionally reference it, but the mandatory stacking of uninsured motorist coverage seems to be largely accepted and not a frequent subject of litigation. See First Nat. Ins. Co. of Am. v. Clark, 899 S.W.2d 502 521-22 (Mo. banc 1995) (discussing liability coverage); Shepherd v. Am. States Ins. Co., 671 S.W.2d 777, 778 (Mo. banc 1984) (disallowing an exclusion for named insured in uninsured coverage and reaffirming Cameron); Long v. Shelter Ins. Co., No. WD 73037, 2011 WL 3106966, at *3 n.4, (Mo. App. W.D. Jul. 26, 2011) (discussing underinsured coverage); Harris v. Shelter Mut. Ins. Co., 141 S.W.3d 45, 62 (Mo. App. W.D. 2004) (discussing underinsured coverage); Niswonger v. Farm Bureau Town & Country, 992 S.W.2d 308, 313 (Mo. App. E.D. 1999) (discussing underinsured coverage); Nolan v. Am. States Preferred Ins. Co., 851 S.W.2d 720, 723 (Mo. App. S.D. 1993) (discussing underinsured coverage).
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