Erie Insurance v. Harding, M.

CourtSuperior Court of Pennsylvania
DecidedOctober 22, 2024
Docket99 MDA 2024
StatusUnpublished

This text of Erie Insurance v. Harding, M. (Erie Insurance v. Harding, M.) 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 v. Harding, M., (Pa. Ct. App. 2024).

Opinion

J-A15005-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

ERIE INSURANCE EXCHANGE : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : BRAD AND MELISSA HARDING, : INDIVIDUALLY AND AS : ADMINISTRATORS OF THE ESTATE : No. 99 MDA 2024 OF DANIEL BLAKE HARDING : : Appellants :

Appeal from the Order Entered January 8, 2024 In the Court of Common Pleas of Lycoming County Civil Division at No(s): CV-2023-00668-CV

BEFORE: DUBOW, J., BECK, J., and STEVENS, P.J.E.*

MEMORANDUM BY DUBOW, J.: FILED: OCTOBER 22, 2024

Appellants, Brad and Melissa Harding (“Father” and “Mother,”

respectively), individually and as administrators of the Estate of Daniel Blake

Harding (“Son”), appeal from the January 8, 2024 order entered by the

Lycoming County Court of Common Pleas, which granted judgment on the

pleadings to Appellee, Erie Insurance Exchange (“Erie”), in this declaratory

judgment action involving the underinsured motorist (“UIM”) coverage

applicable to Son’s fatal motorcycle accident. Based upon its interpretation of

the policy language, the trial court determined that Mother’s policy with Erie

(“Mother’s Policy”), which covered Son’s motorcycle, provided UIM coverage

for Son’s accident but limited the recovery to the UIM limits elected by Mother. ____________________________________________

* Former Justice specially assigned to the Superior Court. J-A15005-24

The court also concluded that the stacked UIM coverage elected by Mother did

not apply because Son did not reside in Mother’s household. After careful

review, we affirm the trial court’s grant of Erie’s motion for judgment on the

pleadings to the extent it required application of the lower UIM limits

requested by Mother but reverse the order to the extent the court failed to

stack UIM coverage; we instead remand to the trial court to grant Appellants’

motion for judgment on the pleadings on the stacking issue and to take any

other action consistent with this decision.

The following are the relevant facts and procedural history. On April 7,

2023, Son died in a motorcycle accident. At the time of the accident, Son

resided with Father, but insured his motorcycle under Mother’s Policy with

Erie. The Estate recovered under the third-party tortfeasor’s insurance policy

and the stacked limits of UIM coverage under Father’s Erie policy. Erie offered

the Estate $100,000, which was the UIM coverage limit elected by Mother for

the motorcycle; Erie, however, refused to provide stacked UIM coverage on

the four vehicles (including the motorcycle) covered on the policy, which would

have resulted in either a total of $400,000, or a total of $1 million, depending

on the applicability of Mother’s election of lower UIM limits. Erie claimed that

the stacked UIM coverage was only available to Mother as the “named insured”

or to any “resident relatives,” which did not apply to Son as he resided with

Father. Appellants, in contrast, argued that stacked UIM coverage applied

because Son was named as an “insured” in the policy based upon the following

-2- J-A15005-24

phrase describing the ownership of a vehicle: “DANIEL & MELISSA HARDING-

CHILD/INSURED[.]” Mother’s Policy, Declarations at 3.

On June 21, 2023, Erie filed a declaratory judgment action against

Appellants to address the coverage issues. Erie and Appellants both filed

motions for judgment on the pleadings. On January 8, 2024, the trial court

granted Erie’s motion for judgment on the pleadings and denied Appellants’

cross-motion.

On January 18, 2024, Appellants filed their notice of appeal. Appellants

and the trial court complied with Pa.R.A.P. 1925.

Appellants raise the following questions on appeal:

1. Is the Estate[] entitled to stacked UIM benefits under the Erie Policy even though [Son] was an insured within the meaning of the Pennsylvania Motor Vehicle Financial Responsibility Law?

1a. In the alternative, did the trial court err by failing to allow the parties to develop an evidentiary record surrounding the parties’ intent and expectations regarding the scope of coverage under the Erie Policy?

2. Did the UIM sign-down form executed by only [Mother], by its plain language, only reduce the limits of UIM coverage for [Mother] and members of her household?

A.

“Appellate review of a trial court’s decision to grant or deny judgment

on the pleadings is limited to determining whether the trial court committed

an error of law or whether there were facts presented which warrant a jury

trial.” Bowman v. Sunoco, Inc., 986 A.2d 883, 886 (Pa. Super. 2009)

(citation omitted). A trial court should grant “judgment on the pleadings only

-3- J-A15005-24

if the moving party’s right to succeed is certain and the case is so free from

doubt that trial would clearly be a fruitless exercise.” Tibbitt v. Eagle Home

Inspections, LLC, 305 A.3d 156, 159 (Pa. Super. 2023) (citation omitted).

As with the trial court, “we confine our review to the pleadings and relevant

documents, and we accept as true all well-pleaded statements of fact in favor

of the non-moving party.” Baumbach v. Lafayette Coll., 272 A.3d 83, 88

(Pa. Super. 2022).

This case involves the interpretation of Mother’s insurance policy, which

presents “a pure question of law subject to a plenary scope of review and a

de novo standard of review.” Kramer v. Nationwide Prop. & Cas. Ins. Co.,

313 A.3d 1031, 1039 (Pa. 2024). As with any contract, our goal is to

“ascertain the intent of the parties as manifested by the terms used in the

written insurance policy.” 401 Fourth St., Inc. v. Invs. Ins. Grp., 879 A.2d

166, 171 (Pa. 2005). While courts apply the plain language when it is

unambiguous, we construe ambiguous language “in favor of the insured to

further the contract’s prime purpose of indemnification and against the

insurer, as the insurer drafts the policy, and controls coverage.”

Pennsylvania Nat. Mut. Cas. Ins. Co. v. St. John, 106 A.3d 1, 14 (Pa.

2014) (citation omitted). “Contract language is ambiguous if it is reasonably

susceptible to more than one construction and meaning.” Id.

In interpreting policy language, we “will not consider merely individual

terms utilized in the insurance contract, but the entire insurance provision to

ascertain the intent of the parties.” 401 Fourth St., Inc., 879 A.2d at 171.

-4- J-A15005-24

When faced with ambiguous policy language, courts will consider “the

reasonable expectations of the insured.” Nationwide Mut. Ins. Co. v.

Nixon, 682 A.2d 1310, 1313 (Pa. Super. 1996). Moreover, it is well-

established that policy provisions “in conflict with, or repugnant to, statutory

provisions[,]” such as the Motor Vehicle Financial Responsibility Law

(“MVFRL”), “must yield to the statute, and are invalid, since contracts cannot

change existing statutory laws.” Prudential Prop. & Cas. Ins. Co. v.

Colbert, 813 A.2d 747, 751 (Pa. 2002) (citation omitted).

The relevant provision of the MVFRL is Section 1738, which addresses

stacking of UIM benefits:

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