Supreme Court finds no uninsured motorist coverage for woman who died in crash

A Missouri woman whose daughter died in a vehicle crash is not entitled to underinsured motorist cover-age following the crash, the Missouri Supreme Court ruled June 4.

The court unanimously held that Chelsea Seaton, the daughter of plaintiff Leslie Seaton, was not a defined insured person under two of her mother’s three automobile insurance policies with Shelter Insurance Co.

According to the opinion, Chelsea Seaton died while riding in another person’s vehicle. The driver lost control of the vehicle and crashed, and Seaton suffered fatal injuries.

The Missouri Supreme Court. File Photo.

After the crash, Leslie Seaton brought a wrongful-death claim against the driver, who eventually settled the claim for her insurance policy’s limits.

Leslie Seaton additionally sought UIM coverage from Shelter under the three insurance policies she maintained from the company. The insurer provided coverage under one of the three policies, but it said Chelsea Seaton was not a defined insured for UIM coverage for the other two.

Leslie Seaton filed a declaratory-judgment action in St. Louis County Circuit Court in 2015 against Shelter, arguing that UIM coverage existed for her daughter under the two policies.

Judge Joseph L. Walsh III granted sum-mary judgment to Seaton. Shelter appealed the ruling to the Eastern District Court of Appeals, which affirmed the judgment. The insurer then appealed to the Missouri Supreme Court.

Shelter argued that Chelsea Seaton did not qualify as an insured under the two policies and also that Walsh erred in entering a judg-ment for Leslie Seaton because he found the policies to be internally inconsistent.

On the first point, Shelter argued that Chelsea Seaton does not meet any of the three definitions of “insured” set forth in the policies.

The policy defined “insured” to include the named insured on a policy; any “rela-tive;” and any individual occupying an in-sured vehicle who is listed as an “additional listed insured” if neither the individual nor their spouse owns a motor vehicle.

Leslie Seaton argued that an average person would believe her daughter is a relative under the policies. The court, however, said the policies’ definition of relative excludes anyone who owns his or her own vehicle. Judge George W. Draper III, who authored the opinion, noted Leslie Seaton admitted in a court filing that her daughter owned a motor vehicle.

“To ‘own’ a motor vehicle, the person only has to hold title to it and may do so in conjunction with other owners,” Draper wrote.

Additionally, the Supreme Court ruled that at the time of the crash, Chelsea Seaton was not an occupant of either vehicle insured under the two policies and thus not entitled to UIM coverage.

Draper wrote that the court did not need to consider Shelter’s argument about in-ternally inconsistent policies because the insurance policies extend coverage only to insured individuals.

“Decedent does not meet the definition of an insured,” he wrote. “Hence, the insurance policies are not internally inconsistent merely because they restrict UIM coverage to insured persons only.”

Jim Ribaudo of Gausnell, O’Keefe & Thompson in St. Louis represented Shelter.

“I think it was the ruling that we were looking for,” he said. “I told my client I was a little surprised it was a unanimous case.”

Ribaudo said the case is in line with oth-er recent insurance-related rulings from the court.

Joseph L. Bauer Jr. of The Bauer Law Firm in St. Louis represented Seaton. He said he had hoped for a different ruling but accepts the court’s decision.

“I know they reviewed the law, and there were some decisions from the Supreme Court that came between when the trial judge granted our motion for summary judgment and now,” he said. “That sort of changed the law, and I think that this deci-sion follows those more recent cases. It’s a different legal landscape than it was when Judge Walsh in the circuit court made his decision.”

The case is Seaton v. Shelter Mutual In-surance Co., SC97511.