Lakes v. Grange Mut. Cas. Co.

Several family members were injured in a car accident and divided the benefits paid by the tortfeasor's insurer. One family member, Hannah Lakes, also sought to recover under the underinsured motorist (UIM) endorsement of an insurance policy provided by Grange Mutual Casualty Company that applied to all the family members involved in the accident. The trial court granted Grange's motion for summary judgment, holding that the tortfeasor's vehicle was not underinsured because the per-accident limit of his policy was equal to the UIM coverage under the family members' policy. The Supreme Court reversed after reaffirming its decision in Corr v. American Family Insurance, holding that the tortfeasor's vehicle was underinsured because the amount actually paid to Lakes was less than the per-person limit of liability of the under-insurance endorsement.