Wallace v. Balint

Summary

The Ohio Supreme Court addresses the validity and application of anti-stacking provisions in multiple underinsured-motorist policies arising from a fatal automobile accident. The court holds that the decedent’s estate and parents may recover under only one separately held policy each, while two other family members may recover under their own policies. It further holds that the parents’ claims and all claims against the tortfeasor’s liability policy are limited to the applicable per-person limits, and remands the case for further proceedings.

Holdings

1. The State Farm policies contained valid antistacking provisions authorized by former R.C. 3937.18(G)(2). Those provisions barred the estate and James and Wanda Wallace from aggregating multiple policies under which they were insured, but did not bar Christopher and Katrina Wallace from recovering under their own separately held policies or bar James and Wanda from coverage under one policy held in their own names.
2. James and Wanda Wallace were together limited to one claim subject to the per-person limit of a single underinsured-motorist policy.
3. The Wallaces' claims against Balint's liability policy were collectively limited to one claim subject to the policy's per-person limit.
4. The court declined to apply the reasonable-expectations doctrine because a majority of the court was not willing to adopt it.

Questions Presented

1. Whether the antistacking provisions in the State Farm policies were valid and whether they barred the Wallace family members from recovering under policies separately held by other family members.
2. Whether James and Wanda Wallace were collectively limited to the per-person limit of a single underinsured-motorist policy or could recover up to the policy's per-accident limit.
3. Whether the claims against Balint's liability policy were collectively limited to the per-person limit.
4. Whether the reasonable-expectations doctrine should invalidate or limit the relevant insurance-policy provisions.

Disposition

reversed_and_remanded