Broderick v. Dairyland Ins. Co.

Appellant was physically injured as a result of an accident caused by an underinsured motorist. Prior to the accident, Appellant purchased a Dairyland Insurance Policy through his insurance agent, Jonathan Schrack. Although Appellant requested full coverage, the policy did not include underinsured motorist coverage. When the other driver's insurance did not fully cover Appellant's damages, Appellant sued Dairyland and Schrack (Defendants), raising numerous theories as to why he should recover under the Dairyland policy. The district court granted Defendants' motions for summary judgment. The Supreme Court affirmed, holding, inter alia, (1) Wyoming's uninsured motorist statutes unambiguously do not require insurers to provide underinsured motorist liability coverage; (2) Appellant's failure to read the policy was available as a defense to Defendants as to Appellant's negligence and contract claims against them and barred application of the doctrine of promissory estoppel; and (3) the doctrine of reasonable expectations was not available to alter the unambiguous terms of the policy.