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Wyatt v. Robin

Citations: 509 So. 2d 746; 1987 La. App. LEXIS 9508Docket: No. 86-603

Court: Louisiana Court of Appeal; May 13, 1987; Louisiana; State Appellate Court

Narrative Opinion Summary

The case involves an appeal concerning the 'stacking' of uninsured motorist (U/M) coverages following an accident involving the appellant, Louis Wyatt, Jr. After settling claims with the at-fault driver and an insurer, Wyatt sought additional U/M benefits from policies held by his father with multiple insurers. The defendants moved for summary judgment, invoking La.R.S. 22:1406(D)(1)(c), which prohibits stacking U/M coverages. The trial court dismissed Wyatt's claims, limiting recovery to the U/M policy of the vehicle involved, aligning with the Breaux precedent, which restricts U/M coverage to the policy specifically covering the vehicle in the accident. Wyatt argued that settling with one insurer should not bar recovery under other policies, citing Branch v. O’Brien. However, the court reiterated Breaux’s authority, emphasizing that only the U/M coverage on the vehicle listed in the accident policy applies. The court distinguished this case from Taylor v. Tanner, where circumstances allowed recovery from a policy with higher limits. The appellate court affirmed the trial court's decision, dismissing Wyatt's appeal and assessing costs against him, thereby reinforcing the prohibition against stacking U/M coverage limits under the applicable statute and case law precedent.

Legal Issues Addressed

Exclusive Source of Uninsured Motorist Coverage

Application: The court affirmed that U/M coverage is limited to the policy of the vehicle involved in the accident, as established in Breaux v. Louisiana Farm Bureau Mut. Ins. Co.

Reasoning: The court in Breaux rejected the reasoning in Branch regarding uninsured motorist (UM) coverage, emphasizing that when there are multiple liability policies but only one that lists the vehicle involved in the accident, that policy's UM coverage is exclusive.

Precedential Authority of Breaux v. Louisiana Farm Bureau Mut. Ins. Co.

Application: The Breaux precedent was used to affirm that only the U/M policy on the involved vehicle provides coverage, rejecting claims based on other policies.

Reasoning: The precedent set in Breaux v. Louisiana Farm Bureau Mut. Ins. Co. reinforced that only U/M coverage under the policy listing the involved vehicle is applicable.

Prohibition of Stacking Uninsured Motorist Coverage under La.R.S. 22:1406(D)(1)(c)

Application: The prohibition against stacking U/M coverages was applied to deny the plaintiff additional benefits beyond the U/M policy on the vehicle involved in the accident.

Reasoning: The trial court dismissed Wyatt's claims, affirming the anti-stacking rule that limits recovery to the primary U/M coverage of the vehicle occupied at the time of the accident.