Lewis v. Allstate Insurance Co., 368 Md. 44

Summary

The Maryland Court of Appeals held that an automobile insurance policy provision reducing uninsured motorist benefits by medical payments previously paid under a separate endorsement was not authorized by Maryland law and was therefore void. The court reversed the Court of Special Appeals and remanded for entry of judgment for the full jury verdict of $11,154.00. The decision emphasized that statutory insurance coverage reductions and exclusions must be expressly authorized by the Legislature.

Holdings

1. Maryland's motor vehicle insurance statutes do not authorize reducing uninsured motorist benefits by the amount previously paid under a medical payments endorsement.
2. The policy language authorizing the reduction is void, and the judgment may not be reduced by the $5,000 medical-payments payment.

Questions Presented

1. Whether Maryland's motor vehicle insurance statutes authorize an uninsured motorist policy provision reducing benefits by medical payments previously paid under a separate medical payments endorsement.
2. Whether the policy provision providing for that reduction is valid and enforceable.

Disposition

reversed_and_remanded