Erie Insurance Exchange v. Beutler, S.

CourtSuperior Court of Pennsylvania
DecidedJune 16, 2026
Docket2095 EDA 2025
StatusUnpublished
AuthorKing

This text of Erie Insurance Exchange v. Beutler, S. (Erie Insurance Exchange v. Beutler, S.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Erie Insurance Exchange v. Beutler, S., (Pa. Ct. App. 2026).

Opinion

J-A08026-26

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

ERIE INSURANCE EXCHANGE : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : SARA C. BEUTLER, INDIVIDUALLY : AND IN HER CAPACITY AS THE : ADMINISTRATOR OF THE ESTATE OF : No. 2095 EDA 2025 RANDOLF BEUTLER, DECEASED, AND : ESTATE OF RANDOLF S. BEUTLER, : BY AND THROUGH ITS : ADMINISTRATOR : : Appellants

Appeal from the Order Entered July 2, 2025 In the Court of Common Pleas of Chester County Civil Division at No(s): 2024-10894-MJ

BEFORE: LAZARUS, P.J., PANELLA, P.J.E., and KING, J.

MEMORANDUM BY KING, J.: FILED JUNE 16, 2026

Appellants, Sara C. Beutler, individually and in her capacity as the

administrator of the estate of Randolf S. Beutler (“Decedent”), and the estate

of Decedent through its administrator, appeal from the order entered in the

Chester County Court of Common Pleas, which granted summary judgment in

favor of Appellee, Erie Insurance Exchange, in this declaratory judgment

action. We affirm.

The relevant facts and procedural history of this matter are as follows.

Decedent and Mrs. Beutler owned four automobiles and a motorcycle.

Appellee issued an insurance policy covering the four automobiles. J-A08026-26

Progressive issued an insurance policy to cover the motorcycle. On August

24, 2018, Decedent executed a waiver of stacked coverage. At the time of

the waiver, there were four vehicles insured under the policy: Auto 1, a 2009

Kia Spectra; Auto 2, a 2001 Toyota Tacoma; Auto 3, a 2017 Hyundai Tucson;

and Auto 4, a 2016 Toyota Tundra. On March 21, 2024, Erie issued an

amendment to the insurance policy, titled “Declarations” (amended), in which

Auto 3 was deleted from the policy, and Auto 5 (a 2024 Toyota Rav4) was

added to the policy.

On April 29, 2024, Decedent was struck from behind by a motor vehicle

while riding his motorcycle on the highway. He died as a result of the accident.

Subsequently, Appellants made a claim for underinsured motorist (“UIM”)

benefits under the Progressive policy. Progressive tendered the full UIM limit

of $300,000.00. Thereafter, Appellants made a claim for stacked UIM benefits

under the Erie policy.

On December 5, 2024, Appellee brought a declaratory judgment action

under the Pennsylvania Motor Vehicle Financial Responsibility Law, 75

Pa.C.S.A. §§ 1701-1799.7 (“MVFRL”). Appellee stated that it had issued a

policy to Decedent, which provided $100,000.00 per person or $300,000.00

per accident in UIM coverage. Under the policy, Decedent had executed a

valid stacking waiver on August 24, 2018. Further, Appellee contended that

the March 21, 2024 amendment had not constituted a purchase of new

coverage. Rather, despite substitutions of vehicles, the policy always covered

four vehicles as well as provided for $100,000.00 per person/$300,000.00 per

-2- J-A08026-26

accident in UIM coverage. As a result, no new stacking waiver was required.

Appellee asserted that none of the four insured vehicles was involved in the

accident. On that basis, Appellee sought a declaratory judgment in its favor

finding that Appellants were not entitled to stacked UIM coverage under the

policy, and, thus, Appellants were entitled to recover solely $100,000.00 in

UIM benefits under the policy. See 75 Pa.C.S.A. § 1738(c).

On January 15, 2024, Appellants filed their answer with a new matter

and counterclaim, demanding that the court permit Appellants to pursue

stacked UIM benefits in the amount of $400,000.00. Appellants specifically

denied that the August 24, 2018, stacking waiver referenced in Appellee’s

complaint was applicable to the coverages in effect at the time of the April 29,

2024 accident. Appellants contended that Appellee deleted and added

vehicles to the policy from August 2018 to April 2024. Appellants further

contended that, when policy changes were made on March 21, 2024, Appellee

was required to offer an additional stacking waiver, and, since Appellee failed

to do so, there was no valid stacking waiver in effect at the time of the

accident. Accordingly, Appellants averred Appellee had an obligation to

provide UIM stacked coverage of $100,000.00 per person/$300,000.00 per

accident with four vehicles, thus, providing a total of $400,00.00 in UIM

coverage under the policy.

In their counterclaim, Appellants alleged Appellee caused the policy to

be changed in March of 2024 to provide Appellee with the greatest benefit and

to the detriment of the insureds. Specifically, Appellants alleged that, in the

-3- J-A08026-26

March 21, 2024, “Declarations” (amended) page, Appellee used the phrasing

“deleting” and “adding” an auto as opposed to “substituting” an auto. As a

result, Appellants insisted that Appellee was required to obtain a stacking

waiver when the March 21, 2024 policy changes were made, and that the

named insureds did not execute such a waiver. Appellants alleged that due

to this failure, Appellee had an obligation to provide UIM stacked coverage.

Thus, Appellants sought a declaratory judgment in their favor and against

Appellee.

On February 21, 2025, Appellee filed a reply to the new matter and

counterclaim. While Appellee admitted that an amendment had been made

to the policy, it expressly denied that it had caused or unilaterally chose to

amend the policy. Rather, Appellants had requested the deletion and addition

of vehicles, as well as decided the type and amount of coverage under the

policy. Thus, the amendment did not constitute a purchase of new coverage

under Subsection 1738(c) of the MVFRL, since the number of vehicles and the

amount of UIM coverage for each vehicle insured under the policy remained

the same.

On May 23, 2025, Appellee filed a motion for summary judgment,

essentially reiterating its prior assertions that the August 24, 2018 stacking

waiver remained in place at the time of the accident. At the time of the waiver,

the policy insured four vehicles, and at the time of the March 21, 2024

amendment, it continued to insure four vehicles. Appellee averred there was

no dispute that Appellee did not charge a premium for a fifth vehicle, and the

-4- J-A08026-26

UM/UIM coverage remained the same prior to and after the March 21, 2024,

“Declarations” (amended). Appellee contended that Subsection 1738(c) of

the MVFRL states that when purchasing uninsured (“UM”) or UIM coverage for

more than one vehicle under a policy, the named insured shall be provided

the opportunity to waive the stacked limits of coverage. However, because

Decedent did not purchase coverage during the 2024 amendment, Appellee

had no obligation to provide the insureds with new stacking waivers.

Accordingly, Appellee averred there was no genuine issue of material fact,

and, as a matter of law, Appellants were entitled to solely $100,000.00 in UIM

coverage.

That same day, Appellee filed a motion for protective order, claiming

that it had produced a full and complete response to Appellants’

interrogatories, but Appellants had served Appellee with a letter of deficiency

seeking specific, supplemental written discovery. Appellee contended the

additional discovery requests sought confidential, proprietary business

information concerning Appellee’s internal business practices, training

protocols, unrelated underwriting materials, and internal discussions within

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