The case revolves around a car accident that occurred on February 6, 2016, involving Melissa A. Keller and her daughter, Caroline Keller, who were insured by State Farm Mutual Automobile Insurance Company. The Kellers were hit by Xavier Blanchard, who ran a red light. Xavier's vehicle was owned by his father, Harvey Blanchard, and was also insured by State Farm. The Kellers filed a complaint against the Blanchards on January 8, 2018, alleging negligence and wantonness. However, the complaint did not state any claim against State Farm. On January 26, 2023, the Kellers settled their claims with the Blanchards and subsequently filed an "Amended Complaint for Underinsured Motorist Coverage" against State Farm on January 27, 2023.
State Farm moved to dismiss the new complaint, arguing that it was filed outside the six-year statute-of-limitations period applicable to contract-based claims. The insurer contended that the claim did not relate back to the original complaint as Keller knew or should have known that State Farm was her insurer. Keller, on the other hand, argued that her claim for underinsured-motorist coverage did not accrue until the date she settled with the Blanchards. The trial court denied State Farm's motion to dismiss on June 12, 2023, without making specific findings of fact or law.
The Supreme Court of Alabama granted State Farm's petition for a writ of mandamus, directing the trial court to dismiss Keller's underinsured-motorist claim against it. The court held that the accrual date for a direct uninsured/underinsured-motorist claim against an insurer is the date of the accident. Since Keller did not assert her direct claim for underinsured-motorist benefits against State Farm until more than six years after the date of the accident, that claim was time-barred. View "Ex parte State Farm Mutual Automobile Insurance Company" on Justia Law
The post Ex parte State Farm Mutual Automobile Insurance Company appeared first on Justia Alabama Supreme Court Opinion Summaries.