James Purk, and Loretta Purk v. Farmers Insurance Company, Inc., and Christopher Wilson

CourtMissouri Court of Appeals
DecidedMay 25, 2021
DocketED109191
StatusPublished

This text of James Purk, and Loretta Purk v. Farmers Insurance Company, Inc., and Christopher Wilson (James Purk, and Loretta Purk v. Farmers Insurance Company, Inc., and Christopher Wilson) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Purk, and Loretta Purk v. Farmers Insurance Company, Inc., and Christopher Wilson, (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION THREE

JAMES PURK, ) ) Plaintiff, ) No. ED109191 ) and ) ) LORETTA PURK, ) ) Appeal from the Circuit Court Plaintiff/Respondent, ) of the City of St. Louis ) Case No. 1822-CC11565 vs. ) ) FARMERS INSURANCE ) COMPANY, INC., ) Honorable Joan L. Moriarty ) Defendant/Appellant, ) ) and ) Filed: May 25, 2021 ) CHRISTOPHER WILSON, ) ) Defendant. )

The defendant, Farmers Insurance Company, Inc. (“Farmers”), appeals the grant of

partial summary judgment entered by the Circuit Court of the City of St. Louis in favor of the

plaintiff, Loretta Purk, in this lawsuit seeking damages for personal injuries sustained by Mrs. Purk and her husband, James Purk, in a motor vehicle accident with an uninsured driver.1 At

issue in this appeal is the maximum amount of uninsured motorist coverage available to Mrs.

Purk under three Farmers’ automobile insurance policies, each of which sets forth coverage

limits of $100,000 per person on the declaration page.

We reverse the trial court’s determination that the policies are ambiguous, and that as a

result, Mrs. Purk is entitled to up to $300,000 in uninsured motorist coverage. We conclude there

is no ambiguity between the owned-vehicle exclusion and other provisions in the insurance

policies. The Farmers policies provide a combined—or stacked—total of $150,000 in uninsured

motorist coverage for Mrs. Purk. There is no dispute that Mrs. Purk is entitled to the policy limits

of $100,000 under the policy on the GMC involved in the accident. We find Mrs. Purk is also

entitled to stack an additional $50,000 in uninsured motorist coverage as a result of the owned-

vehicle exclusion contained in each of the other two policies. The exclusion provides Mrs. Purk

$25,000 in coverage from each of the other two policies, which represents the minimum

coverage required under the Missouri Motor Vehicle Financial Responsibility Law.

Factual and Procedural Background

This appeal arises out of a dispute regarding the amount of uninsured motorist (“UM”)

coverage available under three Farmers policies owned by the Purks for injuries they sustained in

an auto accident. On February 21, 2018, Mr. Purk was driving a 2001 GMC Jimmy, and Mrs.

Purk was a passenger. As the Purks’ vehicle entered a northbound turn lane to make a left turn,

Christopher Wilson drove southbound in the turn lane while attempting to pass other traffic.

Wilson collided head-on with the Purks’ vehicle, injuring both Mr. and Mrs. Purk. Wilson and

the vehicle he was driving carried no automobile liability insurance at the time of the accident,

1 For the reasons explained later in this opinion, Farmers appeals only the grant of partial summary judgment in favor of Mrs. Purk.

2 and Wilson has defaulted in this lawsuit. The parties stipulated that Mrs. Purk sustained damages

in the amount of $300,000, and that Mr. Purk sustained damages of at least $150,000.

At the time of the accident, the Purks were insured under three separate automobile

insurance policies issued by Farmers. The separate insurance policies covered the GMC

(involved in the accident), and two other vehicles, a Dodge Ram, and a Mazda 3 (not involved in

the accident). The declaration page for each policy listed uninsured motorist bodily injury

coverage with limits of $100,000 per person. With few exceptions not at issue here, the policies

are substantially the same, and each policy contains an owned-vehicle exclusion provision.

In addition to negligence claims against the other driver, Mr. and Mrs. Purk brought suit

against Farmers for breach of contract, vexatious refusal to pay, and breach of good faith and fair

dealing when Farmers refused to pay $300,000 in UM policy limits to each of them for their

bodily injuries. The Purks argued that they had the right to stack the $100,000 per person UM

policy limits in each of the three policies. Farmers disagreed, arguing that while the GMC policy

provides $100,000 in UM coverage, the two additional polices limit UM coverage under the

owned-vehicle exclusion to $25,000 under the Dodge policy, and $25,000 under the Mazda

policy for a total of $150,000 per person. The $25,000 represents the minimum UM coverage

required by the Missouri Motor Vehicle Financial Responsibility Law.

The Purks dismissed their claims against Farmers for bad faith and vexatious refusal to

pay. With regard to the breach of contract claims, the Purks and Farmers filed competing

motions for partial summary judgment to resolve the dispute over the amount of available UM

coverage under the Dodge and Mazda policies. The trial court granted the Purks’ motion for

partial summary judgment, and denied Farmers’ motion. The trial court stated, “the insurance

policy is ambiguous. The policy includes both provisions expressly excluding the stacking of

3 multiple uninsured motorist coverages in violation of Missouri law, and allowing for stacking ….

This Court must resolve the ambiguity in favor of coverage.”

Farmers filed a motion with the trial court asking it to certify its judgment in favor of

Mrs. Purk as final for purposes of appeal in accordance with Rule 74.01(b). Both Mr. and Mrs.

Purk consented to certification, and the trial court granted Farmers’ motion, expressly finding no

just reason for delay. Mrs. Purk then dismissed her remaining negligence claims against the other

driver, thus resolving all claims involving her. Farmers appeals.

Rule 74.01(b) Certification

Before addressing the merits of this appeal, we have a duty to determine whether this

Court has jurisdiction. Wilson v. City of St. Louis, 600 S.W.3d 763, 765 (Mo. banc 2020). A

judgment is appealable as a “final judgment” under section 512.020(5) RSMo. (2016) when it

resolves every claim, or at least the last unresolved claim, in a lawsuit.2 Id. at 767-68. Rule

74.01(b) provides an exception to this general rule: the trial court may certify for immediate

appeal a judgment resolving one or more, but fewer than all, of the claims or parties when the

court expressly finds no just reason for delay of the appeal until all claims are resolved. Id. at

768.

A “final judgment” for purposes of appeal under section 512.020(5) must satisfy the

following criteria. Id. at 771. First, it must actually be a judgment, meaning that it must fully

resolve at least one claim in a lawsuit, and must establish all the rights and liabilities of the

parties with respect to that claim. Id. Second, the judgment must be “final,” either because it

disposes of all claims—or the last claim—in a lawsuit, or because it has been certified for

immediate appeal pursuant to Rule 74.01(b). Id.

2 All statutory references are to RSMo. (2016) except as otherwise indicated.

4 A judgment is eligible for Rule 74.01(b) certification only if it disposes of a “judicial

unit” of claims, meaning it either: (a) disposes of all claims by or against at least one party, or (b)

disposes of one or more claims that are sufficiently distinct from the remaining claims pending in

the trial court. Id. Determining whether these criteria are met is a question of law, and depends

on “the content, substance, and effect of the order” rather than the trial court’s designation. Id.

(quoting Gibson v. Brewer, 952 S.W.2d 239, 244 (Mo. banc 1997)). If, as a matter of law, a

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Bluebook (online)
James Purk, and Loretta Purk v. Farmers Insurance Company, Inc., and Christopher Wilson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-purk-and-loretta-purk-v-farmers-insurance-company-inc-and-moctapp-2021.