Davis v. Nationwide Mutual Insurance Company

CourtDistrict Court, M.D. Pennsylvania
DecidedSeptember 10, 2025
Docket3:24-cv-00328
StatusUnknown

This text of Davis v. Nationwide Mutual Insurance Company (Davis v. Nationwide Mutual Insurance Company) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Davis v. Nationwide Mutual Insurance Company, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA BRIAN DAVIS and SUSAN DAVIS, ; No. 3:24cv328 Plaintiffs : : (Judge Munley) Wi : NATIONWIDE MUTUAL INSURANCE : COMPANY, : Defendant :

MEMORANDUM Underinsured motorists (UIM) coverage provides “protection for persons who suffer injury arising out of the maintenance or use of a motor vehicle and are legally entitled to recover damages therefor from owners or operators of underinsured motor vehicles.” 75 PA. CONS. STAT. § 1731(c). It “help[s] defray the cost of an accident” when tortfeasors have minimal or insufficient bodily injury liability coverage. See Gibson v. State Farm Mut. Auto. Ins. Co., 994 F.3d 182, 184 (3d Cir. 2021). Under the Pennsylvania Motor Vehicle Financial Responsibility Law (“MVFRL”), 75 PA. CONS. STAT. §§ 1701-1799.7, insurers must offer UIM

coverage when issuing an auto insurance policy up to an amount equal to the limits for bodily injury liability coverage. 75 PA. CONS. STAT. §§ 1731(a), 1734, 1736. However, the purchase of UIM coverage by insureds is optional. 75 PA. CONS. STAT. § 1731(a). A named insured may reject UIM benefits, subject to

certain requirements. 75 PA. CONS. STAT. § 1731(c),(c.1). Furthermore, a named

insured may make a written request that an auto policy with UIM coverage be issued in an amount equal to or less than the limits of liability for bodily injury. 75 PA. CONS. STAT. § 1734; see also Geist v. State Farm Mut. Auto. Ins. Co., 49 F.4th 861, 864 (3d Cir. 2022) (citing Gibson, 994 F.3d at 187). Pennsylvania law provides different requirements for rejecting UIM coverage versus selecting an | amount of UIM coverage if purchased. Plaintiffs Brian Davis and Susan Davis bring this declaratory judgment action against Defendant Nationwide Mutual Insurance Company (“Nationwide”), | disputing the total amount of UIM coverage available under their policy. Before the court are cross-filed motions for summary judgment. Nationwide stands firm in its prelitigation position that Plaintiff Brian Davis executed a valid written request to reduce his UIM coverage below his bodily injury limits using a sign- down form. Plaintiffs dispute that this form applies to the Nationwide policy that

was in place when they made a UIM claim. Background | On September 8, 2022, Plaintiff Brian Davis sustained injuries in an auto accident in South Abington Township, Lackawanna County, Pennsylvania.

‘Unless otherwise noted, the factual background derives from the parties’ statements of material facts (hereinafter “PL SOF” and “Def. SOF”) filed pursuant to the Rules of Court for | the Middle District of Pennsylvania. (Docs. 19, 21-2). To the extent the parties' statements are

| (Doc. 19, Pl. SOF 43). At the time, plaintiffs were insured with Nationwide under | policy number 5837J 261 208 (hereinafter “One Product policy”) with an effective period of August 28, 2022 to February 28, 2023. Id. 96. The tortfeasor’s | insurance company tendered her bodily injury liability limits of $20,000 and | plaintiffs accepted with the consent of Nationwide. Id. 4/4. After receiving | payment from the tortfeasor’s policy, plaintiffs then turned to their own UIM | coverage with Nationwide. | The operative declarations page for the One Product policy reflects that, on

| the date of the accident, plaintiffs carried $300,000 in bodily injury coverage for | each person/each occurrence in the event of their own liability. (Doc. 20-2, PI. | Ex. 2 at ECF p. 8-10). The declarations page further indicates that plaintiffs’ UIM limits were $15,000 each person/$30,000 each occurrence (non-stacked) in the event of an accident with an underinsured motorist. Id. To date, Nationwide has paid plaintiffs $45,000 in stacked UIM benefits. * (Doc. 21-2, Def. SOF ¥ 44). | undisputed or supported by uncontroverted record evidence, the court cites directly to the | statements of material facts. The court reviews the evidence in the light most favorable to the non-moving party with respect to each motion. See Lawrence v. City of Philadelphia, Pa., 527 F.3d 299, 310 (3d Cir. 2008) (explaining that the summary judgment standard is no different | when there are cross-motions for summary judgment). ? Plaintiffs’ complaint, initially filed in the Lackawanna Court of Common Pleas, alleged that | Nationwide relied upon certain forms to assert that plaintiffs only had $15,000 in UIM | coverage. (Doc. 1-2 [f] 30, 33). The original complaint maintained two causes of action, one | for a declaratory judgment and one for bad faith. Id. {[f] 27-38. After removal of the action by | Nationwide, (Doc. 1), defendant filed an answer attaching a UIM stacking rejection form. (Doc. | 4-1 at ECF p. 5). |

| Plaintiffs had been insured with Nationwide for many years at the time of

. : |the accident. (Doc. 19, Pl. SOF {[f] 7-9). On August 31, 2001, and in | conjunction with a policy bearing the number 58D362739 (“prior policy”), Brian Davis signed a document entitled “Important Notice” containing language mandated by the MVFRL in 75 PA. CONS. STAT. § 1791 (“1791 Notice”). (Doc. 21-

|2, Def. SOF J 3; see also Doc. 21-24, Def. Ex. S at ECF p. 32). The 1791 Notice

| advised Davis that insurance companies were required by law to make UIM

coverage available for purchase up to at least $100,000 per person and | $300,000 per occurrence. (Doc. 21-24, Def. Ex. S at ECF p. 32). This form | further advised that insurers may offer higher benefit levels and that insureds | may elect to purchase lower benefit levels. Id. Just above Brian Davis's | signature, the 1791 Notice states: “Your signature on this notice or your payment | of any renewal premium evidences your actual knowledge and understanding of po | By stipulation, plaintiffs filed an amended complaint on May 21, 2024, which withdrew the bad | faith claim. (Doc. 13). The amended complaint continued to allege that Nationwide improperly provided plaintiffs with $15,000 in UIM coverage. Id. ff] 30, 33. Nationwide filed an answer to | the amended complaint likewise attaching the UIM stacking rejection form as an exhibit. (Doc. | 14-2, at ECF p. 4). Between May 2024 and November 2024, when the instant motions for summary judgment | were filed, Nationwide either unilaterally paid $45,000 to plaintiffs in stacked UIM coverage or | the parties mutually agreed to resolve the stacking issue. (See Doc. 21-2, Def. SOF □□ 44). | The court will consider that issue resolved and will not draw any inferences in favor or against either party when considering the cross-motions for summary judgment. 4

| the availability of these benefits and limits as well as the benefits and limits you | selected.” Id. (capitalization removed). From that time, the prior policy renewed for successive policy periods through and including a policy period ending on August 31, 2020. (Compare Doc. 21-2, Def. SOF J 3 with Doc. 25, PI. Resp. to Def. SOF 3). In that period of approximately 20 years, Brian Davis also signed multiple documents evidencing his election of UIM coverage below his bodily injury limits, including on January 2019. (Doc. 21-24, Def. MSJ Ex. S at ECF pp. 37, 45, 53, 60, 63). The | parties refer to these documents as sign-down forms.

| The prior policy then changed to the One Product policy as the result of | Nationwide’s business decisions, i.e., something defendant called its One Product Initiative.* (Doc. 20-6, Pl. MSJ Ex. 6, B. Ryan Dep. 21:3-23:2). On June 25, 2020, as part of the One Product Initiative, Nationwide sent plaintiffs a | “Notice of Policy Change” document. (Doc. 19, PI. SOF ¥ 17 (typographical error corrected)). That document included “clarifications” of certain policy terms. (Doc. 20-5, Pl. MSJ Ex. 5 at ECF p. 3).

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