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Attorneys Seth Gausnell and James Ribaudo received a favorable result from the Supreme Court of Missouri in the matter of Seaton v. Shelter Mut. Ins. Co. 574 S.W.3d 245 (Mo. banc 2019). The unanimous decision followed unfavorable results from the Circuit Court of St. Louis County and the Missouri Court of Appeals, Eastern District.

In Seaton, the claimant sought Underinsured Motorists Coverage (“UIM”) under three policies issued by Shelter Insurance. The court ultimately held that the claimant did not qualify as an “insured” under the relevant policies for UIM Coverage.

It was successfully argued on behalf of Shelter that the claimant did not qualify as an “insured” for three reasons. First, the claimant was not listed as a Named Insured on any of the Shelter Policies at issue. Second, the claimant did not qualify as a “relative” on any of the Shelter Policies at issue because the claimant owned a vehicle. Finally, the claimant was not occupying a vehicle insured by any of the Shelter Policies at issue.

The Supreme Court of Missouri agreed with all three arguments made on behalf of Shelter and held that the claimant’s status as an ‘Additional Listed Insured’ did not confer UIM Coverage under the Shelter Policies. The Court further agreed that the claimant could not be considered a “relative” because her ownership of another vehicle was confirmed by the listing of the claimant’s name on a certificate of title to another motor vehicle. Finally, the Court agreed that the claimant was not an occupant in any of the vehicles insured by the Shelter Policies at issue.

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