Williams, C.J.
In these five cases we again consider the validity of the so-called "owned vehicle” exclusion in policies of no-fault automobile insurance.
The claimants in these cases are all insureds under the terms of the policies at issue, in one case because the claimant is the named policyholder and in the remaining cases because the [607]*607policies cover the claimants as relatives residing in the same household as the policyholder.
The policies state that coverage is provided to insured persons while driving "the owned automobile” and also while driving "a nonowned automobile.” The claimants contend that they were each involved in an automobile accident while occupying a nonowned automobile, specifically one owned by a relative residing in the household which was not the vehicle described in the policy in question. The sole exception is the Schiebout case, in which the accident vehicle was owned by a nonresident brother-in-law.
The insurance companies refuse to pay benefits because they claim that the policy definitions of the terms "owned automobile” and "nonowned automobile” exclude insured persons from coverage under the above circumstances. While the policies cover both owned and nonowned automobiles, the insurers state that the cars involved in these accidents do not fit in either category, according to the policy definitions.
I. OVERVIEW
These cases present an interesting problem. The opposing parties, in effect, claim to construe as clear and unambiguous the insurance policies containing the so-called owned-automobile exclusion provisions, with dramatically different results. What is so interesting is that from the perspective of each party, there is demonstrable justification for its position. The claimants argue, somewhat paradoxically, that the exclusion is ambiguous— and therefore void — for the very reason that there are two viable interpretations.
The two viable interpretations are as follows: First, the claimants contend they are entitled to understand plain and common English for its nor[608]*608mal and regular meaning.1 Second, the insurers claim that, if the insurance policy is read in its entirety and construed with understanding, the words are subject to clear and unambiguous definitions which give them a meaning other than the normal and regular meaning perceived by the claimants.
This Court, in approaching the problem, must recognize an insurance contract for what it is. It is not a hard-bargained contract drafted after mutual consideration of the positions of two negotiators with equal or substantially equal skills and resources. What is involved is a contract of adhesion, a take-it-or-leave-it insurance policy not drafted by the buyer or even by the seller of the policy, but by insurance and legal experts of a state, national, or international organization, hundreds and maybe thousands of miles away. It is fatuous to suppose the policy owner had any part in the language of the policy besides filling in the blanks, and the problem in question involves not the blanks, but the established text of the printed form.
The common wisdom is that very few insurance policy purchasers read all or even substantially all of the purchased contract, and it is not guarantee-able that they would understand it if they did. That is not to say that most reasonably competent lawyers with sufficient time, or "insurance specialist” lawyers in shorter time, couldn’t read and understand the policy. However, we do not believe that it is being argued that it would be in the public or any special interest to assume that the purchase of liability insurance for an automobile should require the assistance and cost of an attorney.
The contentions of the two parties ultimately [609]*609boil down to this. The claimant says, the policy in question provides that I am an insured, that the accident is the kind of accident covered, that coverage is provided for such an accident occurring in an owned vehicle or in a nonowned vehicle, and that since "owned” and "nonowned” are common and well-understood English terms, a vehicle must be either owned or nonowned and therefore I am covered.
Not so, says the insurance company. It is true the claimant is an insured and the kind of accident is the type covered, but it is not true that every vehicle is an owned vehicle or a nonowned vehicle. The insurance company then points out that if the policy is carefully read, it will be discovered that in the definitions section of the policy there is a special definition for "nonowned automobile” that reads as follows:
"[N]on-ówned automobile” means an automobile or trailer not owned by or furnished for the regular use of either the named insured or any relative.[2]
The insurance company states that if this definition is carefully read and then read in connection with the definition of "relative,” it will be seen that indeed there is another category beyond owned and nonowned automobiles. The claimants in these cases were not in either an owned or a nonowned automobile, but were in a different category of automobile altogether, and thus insurance coverage was excluded.
It is difficult to deny that both parties make a persuasive case from their particular perspectives. Further, it should be noted that there is no #rgu[610]*610ment that, if properly drafted, some or all of the owned-automobile exclusion isn’t reasonable public policy. For example, there is no good reason why the insurance industry shouldn’t protect itself and its insureds against higher rates by avoiding such risks as policyholders who knowingly try to make a policy intended to cover one car cover two, or a low-risk policy cover a low- and a high-risk as well.3 Protecting against such unpaid-for risks is undoubtedly in the public interest, but that still doesn’t justify such exclusions if they are not clear and properly brought to the policy buyer’s attention. It becomes the Court’s duty, therefore, to determine what the law, justice, and public policy require.
II. ISSUES AND HOLDING
The issues we decide today are:
I. Under the no-fault statute, may an insurance policy exclude residual liability coverage for an insured driving a vehicle not named in the policy which is owned by a resident family member?
II. Is the owned-vehicle exclusion in these cases (a) ambiguous, (b) made clear, (c) a technical construction, and (d) contrary to the insured’s reasonable expectations?
III. If the owned-vehicle exclusion is invalid, should the insurer be liable for only the amount of residual liability coverage required by law, or for the amount provided for in the insurance contract?
We would hold:
I. The owned-automobile exclusion is not repug[611]*611nant per se to the no-fault act, and that insurance policies may therefore exclude residual liability coverage for otherwise-insured resident family members when they drive vehicles owned by other resident family members and not described in the policy.
II. In these cases, the insurers’ method of exclusion — by the definition of terms at variance with their common meaning, which most policyholders would consider clear without definition — renders it invalid as (a) ambiguous, (b) not made clear, (c) a technical construction, and (d) contrary to the reasonable expectations of the insured reading the insurance contract.
III. The liability coverage to be applied is the amount contracted for, and is not limited to the minimum coverage required by law.
III. INTRODUCTION TO ISSUES I AND II
Three of the cases we consider today, Schiebout, Deyarmond, and Nicholson, involve those sections of the subject insurance policies providing for coverage of "residual tort liability.” Because the other two cases, Powers and Dennison, involve different issues, we will treat those cases separately, as well as a secondary issue in Nicholson, which will be considered with the main issue in Dennison.
Under the basic no-fault scheme, insurers are required to pay medical and work-loss expenses incurred by their policyholders resulting from automobile accidents without regard to fault. MCL 500.3105; MSA 24.13105. In cases of serious injury or death, however, victims of traffic accidents may still sue negligent drivers in tort for noneconomic damages. MCL 500.3135; MSA 24.13135. In consequence of this so-called "residual tort liability,” [612]*612the no-fault act requires motor vehicle owners to maintain insurance against the possibility that they will be found liable. MCL 500.3101(1); MSA 24.13101(1).
These no-fault insurance policies provide coverage for the "named insured” and relatives residing in the same household. The insurers intend to provide coverage for the family members’ occasional use of automobiles owned by persons outside the family and outside the home, but to exclude coverage for the family members’ use of automobiles "owned by or furnished for the regular use of,” resident members of the family, other than the car specifically insured by the policy. The insurer’s understandable purpose in excluding coverage in these situations is to avoid a situation in which a person obtains a high level of liability coverage for one automobile in the family, and seeks to use that greater protection to cover liability incurred while the insured is driving a family car with a lower level of coverage or no coverage.
Another purpose for the exclusion of coverage when an insured is driving a vehicle owned by another household member is to prevent "stacking,” that is, recovery from more than one policy in cases in which a person is insured under several family policies.
The insurers here have attempted to both exclude this "free-ride” insurance coverage and stacking by the so-called owned-automobile exclusion method. The policies grant coverage for the named insured and for household relatives while driving an owned or a nonowned car, which, in plain English appears to be totally comprehensive coverage. Although the policy contains a section entitled "Exclusions,” the exclusion at issue here is not contained in that section. The insurers, however, claim exclusion is accomplished by defin[613]*613ing the common and generally clearly understood term "nonowned” in such a way as to refer to less than all nonowned automobiles.
The claimants argue that, because the no-fault act, MCL 500.3101 et seq.; MSA 24.13101 et seq., requires residual liability coverage, MCL 500.3131; MSA 24.13131, the exclusion is repugnant to the statute and must be struck down. Alternatively, they argue that the exclusion must be rejected because it is ambiguous and unclear and also because it defeats the policyholders’ reasonable expectations.
IV. FACTS FOR ISSUES I AND II
Schiebout v Citizens Insurance
Herman Schiebout owned two automobiles which were insured by the defendant. Mr. Schiebout’s brother-in-law owned a business, the Recreational Center of Kent, Inc. The business owned a dump truck which Mr. Schiebout was allowed to use whenever he wished and did use an unspecified number of hours. In the winter of 1980-81, Mr. Schiebout used the dump truck to move a house, and then parked it at his home for the remainder of the winter. On May 21, 1981, he took the truck on the road to see if it would run after having been idle for several months. The truck’s brakes failed and it collided with another vehicle, resulting in injuries to Margaret and Diane Bowers. The dump truck was not insured. When the Bowerses brought suit against Schiebout, he brought an action for declaratory judgment to determine the applicability of his policy with the defendant on his own automobiles, which contained an owned-vehicle exclusion. The trial court held that the accident was covered by Mr. Schiebout’s policy. [614]*614The Court of Appeals affirmed, 140 Mich App 804; 366 NW2d 45 (1985), and this Court granted leave to appeal, 422 Mich 973 (1985).
Deyarmond v Community Service Insurance
On September 12, 1980, William Deyarmond was involved in an automobile accident which took the lives of five members of the Houghton family. William was driving an automobile owned by his mother, Ester, and insured by Citizens Insurance Company. At the time of the accident, William was living with his mother and his brother, Steven. Steven owned an automobile which was insured in his mother’s name by the defendant, Community Service Insurance.
Wrongful death actions have been brought against William and Ester Deyarmond by the five Houghton estates. Citizens tendered its policy limits of $40,000. Ester Deyarmond brought a declaratory judgment action seeking additional coverage under her policy covering Steven’s car. The defendant, Community Service Insurance, claimed coverage was unavailable due to the policy’s owned-automobile exclusion. The trial court found for the plaintiff. Following this Court’s denial of defendant’s application for leave to appeal prior to decision by the Court of Appeals, the Court of Appeals reversed, 132 Mich App 191; 347 NW2d 201 (1984).
We first held the case in abeyance for DAIIE v Widling, 420 Mich 549; 362 NW2d 227 (1984). Following the decision in that case, we granted leave to appeal, 422 Mich 973 (1985).
Auto Club Insurance Association v Nicholson
Paul Nicholson was one of three persons killed [615]*615in an automobile accident which occurred on October 8, 1978. The driver was Keith Kron, who was operating an automobile owned by his sister, Karen. At the time of the accident, Keith and Karen were living with their parents, Gaylord and Jeannette, both of whom owned automobiles. All three family vehicles were insured in separate policies with the Auto Club.
Nicholson’s estate commenced a wrongful death action against Keith and Karen Kron. After litigation, the parties entered into a consent judgment which provided that the Auto Club defendant would pay the policy limits on the policy insuring Karen Kron’s car and would seek a declaratory judgment regarding the coverage of the parents’ policies. In this declaratory action, the circuit court held that the parents’ policies did not cover the accident, because of the owned-automobile exclusion, and the Court of Appeals affirmed, 142 Mich App 168; 368 NW2d 875 (1984). After holding the case in abeyance for Widling, supra, this Court granted leave to appeal, 422 Mich 973 (1985).
V. ISSUE i: IS THE OWNED-VEHICLE EXCLUSION REPUGNANT TO THE NO-FAULT ACT?
This Court considered the issue of the owned-vehicle exclusion in State Farm v Ruuska, 412 Mich 321; 314 NW2d 184 (1982). Three justices in that case would have held that the exclusion was repugnant to the no-fault act. Three other justices were of the opinion that the exclusion was permitted under the act and was, furthermore, unambiguous and should be enforced as written. Justice Levin wrote a separate opinion in which he concluded that, although the no-fault act permitted such an exclusion, the exclusion in that particular case was void because, by defining a commonly [616]*616understood term in an uncommon way the insurer defeated the policyholder’s reasonable expectations.
Since four justices of the Ruuska Court held through the opinions of Chief Justice Coleman and Justice Levin that exclusion of household Vehicles from liability coverage was not contrary to the no-fault statute, that issue was conclusively resolved by that decision. We have been presented no reason or policy to reconsider that holding.
Ruuska also held, through the opinions of Justices Williams and Levin that stacking was permitted. In that case, the daughter lived in her father’s household and was involved in an áccident driving her father’s car. The result in Ruuska allowed the stacking of the father’s policy and the daughter’s policy. That issue is not before us.
VI. ISSUE Ii: IS THE OWNED-VEHICLE EXCLUSION (A) AMBIGUOUS, (B) MADE CLEAR, (C) A TECHNICAL CONSTRUCTION, AND (D) CONTRARY TO THE REASONABLE EXPECTATIONS OF THE INSURED?
Left unresolved by the Ruuska Court is the question we consider today: whether the insurers in these cases may exclude liability coverage for vehicles owned by resident family members by means of a separate and unreferenced limiting definition of the plain English terms, "owned” and "nonowned automobiles”4 so that "nonowned automobile” means less than all nonowned automobiles.
A. PERTINENT INSURANCE PROVISIONS
In these cases, the drivers of the automobiles [617]*617involved in the accidents were insured under the terms of the policies at issue. In Deyarmond and Nicholson, the drivers were insured because they were relatives of the named insured living in the same household. In Schiebout, the driver was the named insured.
The policy language of the four policies at issue in' these three cases is substantially similar. The language of the Deyarmond policy is illustrative. Under the general heading of ‘'Part I — Liability,” the first section is headed:
Coverage A — Bodily Injury Liability ....
[The insurer agrees] [t]o pay on behalf of the insured all sums which the insured shall become legally obligated to pay as damages because of:
A. bodily injury, sickness or disease, including death resulting therefrom, hereinafter called "bodily injury,” sustained by any person; . . . arising out of the ownership, maintenance or use of the owned automobile or any non-owned automobile ....
Persons Insured: The following are insureds under Part I:
(a) with respect to the owned automobile,
(1) the named insured and any resident of the same household,
(b) with respect to a non-owned automobile,
(1) the named insured,
(2) any relative ....
Definitions: Under Part I:
"relative” means a person related to the named insured by blood, marriage or adoption who is a resident of the same household ....
[618]*618"owned automobile” means
(a) a private passenger, farm or utility automobile described in this policy for which a specific premium charge indicates that coverage is afforded.
"non-owned automobile” means an automobile or trailer not owned by or furnished for the regular use of either the named insured or any relative ....
Exclusions: This policy does not apply under Part I:
(a) to any automobile while used as a public or livery conveyance ....
(b) to bodily injury or property damage caused intentionally by or at the direction of the insured;
(c) to bodily injury or property damage with respect to which an insured under this policy is also an insured under a nuclear energy liability policy ....
(d) to bodily injury or property damage arising out of the operation of a farm tractor or farm machinery;
(e) to bodily injury to any employee of the insured ....
(f) to bodily injury to any fellow employee of the insured injured in the course of his employment ....
(g) to an owned automobile while used by any person while such person is employed or otherwise engaged in the automobile business . . . .[5]_
[620]*620B. PERTINENT CASE LAW
We begin our consideration of the validity of the owned-vehicle exclusion by reviewing the pertinent case law of construction of insurance contracts.
In Pietrantonio v Travelers Ins Co, 282 Mich 111; 275 NW 786 (1937), the plaintiff was injured in an automobile in which he was riding as a passenger. The plaintiff, at the time of the accident, was considering purchasing the car, and its owner, who was not in the automobile business, was demonstrating the car to him. The owner’s insurance policy with the defendant contained an exclusion for accidents occurring " 'while the automobile is used in the business of demonstrating or testing.’ ” Id. at 117. This Court held that, although the car was being demonstrated, it could not be said to have been used by its private owner in the "business of demonstrating.” The Court stated:
It is a principle of law too well established in this jurisdiction and others to need discussion or citation of authorities, that a policy of insurance couched in language chosen by the insurer must be given the construction of which it is susceptible most favorable to the insured; that technical constructions of policies of insurance are not favored; and that exceptions in an insurance policy to the general liability provided for are to be strictly construed against the insurer. Pawlicki v Hollenbeck, 250 Mich 38 [229 NW 626 (1930)]. [Id. at 116.]
In Hooper v State Mutual Life Assurance Co, 318 Mich 384, 388; 28 NW2d 331 (1947), this Court considered language in a double-indemnity clause of a life insurance policy that excluded payment under certain circumstances. The policy language stated:
[621]*621"This provision shall not cover homicide or death resulting directly or indirectly from self-destruction or any attempt thereat while sane or insane; or the commission of assault or felony by the insured; combat, war or any act of war; participation in an insurrection, riot, or strike; travel, or flight in any aircraft or balloon, or from being in, on, or about any kind of aircraft or balloon; participation in submarine operations, or descent or riding in a submarine; from any physical or mental disease, illness, or infirmity; from sickness resulting from the eating of any form of food or drinking of any form of liquid; hemophilia; or bacterial infection other than that occurring in connection with, or in consequence of, accidental bodily injuries; or from any kind of poisoning, whether voluntary or otherwise, or asphyxiation; or from carbon monoxide or gas, or fumes, of any kind, voluntary or involuntary, accidental or otherwise, taken, administered, absorbed, or inhaled.”
The insured was a victim of homicide. The plaintiff widow argued that the phrase "resulting directly or indirectly from” modified both "homicide” and "death,” and since the insured’s murder did not fit within one of the exceptions, the double-indemnity provision applied. The insurer claimed that the twelve exceptions pertained only to the word "death,” and that all homicides were excluded from double-indemnity coverage. This Court noted that the insurance company would have the policy language read as though there were a comma or semicolon after the word "homicide,” and held that, construing the provision in the light most favorable to the insured, the phrase "resulting directly or indirectly from” modified either the word "homicide” or the word "death” or both. This Court quoted Boesky Bros Corp v USF & G Co, 267 Mich 628, 629-630; 255 NW 307 (1934):
[622]*622There is no question but that, in a case of ambiguity, the language must be strongly construed against the insurer. The courts have no patience with attempts by a paid insurer to escape liability by taking advantage of an ambiguity, a hidden meaning, or a forced construction of the language in a policy, when all question might have been avoided by a more generous or plainer use of words.
In Francis v Scheper, 326 Mich 441, 445; 40 NW2d 214 (1949), the plaintiff was injured in an automobile accident while being transported home from work by his employer. Under the plaintiff’s employment agreement, he received an hourly wage and transportation to and from work. The garnishee defendant casualty company denied coverage because of a clause in the policy excluding coverage for an employee injured while "engaged in the employment of the insured.” The Court found for the plaintiff, stating:
The phrase, "engaged in the employment,” can fairly be construed as meaning, active in the work plaintiff was employed and paid to do. It was incumbent on defendant casualty company, who drafted the policy, in order to escape liability under the circumstances of this case, so to draft the policy as to make clear the extent of nonliability under the exclusion clause. [Id. at 446-448.]
In DeLand v Fidelity Health & Accident Mutual Ins Co, 325 Mich 9; 37 NW2d 693 (1949), we considered a life insurance policy which contained a prominent notice indicating it was noncancellable. The policy also contained, in a section entitled "Additional Provisions,” a sentence stating that the acceptance of renewal premiums was optional. Faced with the defendant insurer’s claim that it was entitled to refuse to renew the policy, this Court stated:
[623]*623In our judgment the much obscured sentence: "The acceptance of any renewal premium shall be optional with the company” is inconsistent with the much more prominently printed words of the policy heretofore noted and renders the policy not only ambiguous but deceptive, [id. at 17.]
The DeLand Court also quoted Schultz v Benefit Ass’n of Ry Employees of Chicago, 175 SC 182, 187; 178 SE 867 (1934):
"[T]he policyholder must be protected against confusing statements in policies, and, wherever there are two constructions that can be placed upon the policy, the construction most favorable to the policyholder will be adopted.” [DeLand, supra at 18.]
C. SIX RULES DERIVED FROM CASE LAW
In construing the so-called owned-automobile exclusion, we are therefore guided by the following rules found in our case law:
1) "[E]xceptions in an insurance policy' to the general liability provided for are to be strictly construed against the insurer.” Pietrantonio, supra at 116.
2) An insurer may not "escape liability by taking advantage of an ambiguity . . . .” Hooper, supra at 393. " '[Wjherever there are two constructions that cán be placed upon the policy, the construction most favorable to the policyholder will be adopted.’ ” DeLand, supra at 18.
3) An insurer must "so . . . draft the policy as to make clear the extent of nonliability under the exclusion clause.” Francis, supra at 448.
4) An insurer may not "escape liability by taking advantage of ... a forced construction of the [624]*624language in a policy . . . .” Hooper, supra. "[Technical constructions of policies of insurance are not favored . . . .” Pietrantonio, supra.
5) "The courts have no patience with attempts by a paid insurer to escape liability by taking advantage of an ambiguity, a hidden meaning, or a forced construction of the language in a policy, when all question might have been avoided by a more generous or plainer use of words.” Hooper, supra.
6) "[N]ot only ambiguous but deceptive.” "[T]he policyholder must be protected against confusing statements in policies . . . .” DeLand, supra at 17-18.
D. APPLICATION OP RULES OP CASE LAW TO FACTS
Let us now apply these six rules of case law to the policies and facts in the instant cases.
1. Exclusions Construed Against Insurer
At the outset and overall, as held in Pietrantonio, "exceptions in an insurance policy to general liability provided for are to be strictly construed against the insurer.” The issue in these cases involves the owned-automobile exclusion. As a consequence, the owned-automobile exclusion must "be strictly construed against the insurer.”
2. Ambiguities Construed in Favor of Insured
Hooper held an insurer may not "escape liability by taking advantage of an ambiguity.” This rule raises the question most vigorously argued by the parties in the instant cases, i.e., was there an ambiguity so that the policy must be construed in favor of the claimant?
Instant claimants contend that in the plain English of the policy, the accident, they as persons, [625]*625and the automobiles they drove were covered. Insurers contend the automobiles driven were not covered.
Having in mind the policy as set out ante, pp 617-618 except as hereinafter stated, let us review Whether or not there was an ambiguity. We first look to see whether the injury is of the type covered. The excerpt "Coverage A — Bodily Injury Liability,” ante, pp 617-618 covers the injuries in question without doubt.
We next look to see who is insured. Since this is the principal issue here, we reproduce the pertinent text quoted ante, p 617:
Persons Insured: The following are insureds under Part I:
(a) with respect to the owned automobile,
(1) the named insured and any resident of the same household,
(b) with respect to a non-owned automobile,
(1) the named insured,
(2) any relative ....
Reading "Persons Insured” leads to the clear conclusion the claimants here are provided liability coverage. The claimants are either the named policyholder or resident relatives of the policyholder, so with respect to both categories — ‘"owned automobile” and "nonowned automobile” — they are covered. Since the terms "owned automobile” and "nonowned automobile” are terms in common use with unambiguous meanings, claimants argue that there is no reason to look any further.
Moreover, claimants contend that if a "super-cautious” policy reader wanted to make certain there was no pertinent exclusion from coverage, the reader could look at the section on exclusions. [626]*626Examination of that section would reveal no exclusion that is pertinent to the facts in question.
So examination of accident coverage, persons insured and exclusions, claimants contend, indicates that there should be entitlement to liability coverage.
The insurers contend that there is indeed an exclusion from coverage. They say that there is a third category of automobiles in addition to owned automobiles and nonowned automobiles.
The insurers explain this paradox by saying that when their policies use the common term "non-owned automobile,” it has a special meaning for purposes of the policies that requires a policyholder to look beyond the clear and common understanding of the term to the policies’ definitions section. There nonowned automobile is defined as follows:
"[N]on-owned automobile” means an automobile or trailer not owned by or furnished for the regular use of either the named insured or any relative ....
One must also consult the definition of "relative” to see that it means a relative "who is a resident of the same household” as the named insured.
The pieces, as contended by the insurer, are all there and can be put together, if you are an expert specially experienced in these matters.
The question to be decided remains. Are there two constructions, so that the insured’s construction must prevail? It would fairly appear that there is here a real ambiguity, and consequently the claimants’ construction should prevail.
In any event, it is instructive to refer to the policy in the Hooper case, which contained this exclusion: "This provision shall not cover homicide [627]*627or death resulting directly or indirectly from . . .,” followed by twelve specified modifiers as set out ante, p 621. The ambiguity in that case concerned whether the modifiers applied to both "homicide” and "death” or just to the latter. The modifiers included some conditions which would appear to have reference only to "death” and not to "homicide,” for example: "resulting directly or indirectly from . . . travel, or flight in any aircraft or balloon”; "participation in submarine operations”; and "hemophilia.” It certainly was arguable by the insurer, as in the instant cases, that the nature of the modifiers made only the insurer’s construction reasonable, i.e., the modifiers applied only to "death” but not to "homicide.” However, this Court held oppositely and denied the exclusion. The instant cases certainly present greater ambiguity than in Hooper. Therefore, it is reasonable for this Court to invalidate the owned-automobile exclusion in these cases.
3. Policy Must "Make Clear” the Exclusion
Francis, supra at 447-448, held that "[i]t was incumbent on defendant casualty company ... so to draft the policy as to make clear the extent of nonliability under the exclusion clause.” The implication of this rule is not only that ambiguities are to be construed against the insurer, but that the insurer has a positive and affirmative duty to "make clear” any exclusion. The question in Francis was whether an automobile injury to an employee being driven home according to agreement was compensable under an exclusion while "engaged in the employment of the insured.” The insurer, of course, argued that the employee was "engaged in the employment of the insured,” whereas the plaintiff employee argued he was not [628]*628"engaged in employment.” This Court held for the employee and indicated that if the insurer didn’t mean "active in the work plaintiff was employed and paid to do” it was up to the insurer to draft the provision to "make clear” what it wanted to say.
Applying this rule to the instant cases, we discover that there was no reference at all to the so-called owned-automobile exclusion in the exclusions section. Consequently, the insurers are in violation of this rule and the exclusion is invalid unless it can be said that the definition of "non-owned automobile” was not a definition clause but an exclusion clause. If the definition were considered as an exclusion clause, it certainly wouldn’t seem to have been made clear as Francis would require.
4. Liability Not Escaped Through Forced or Technical Construction
Rule 4 is that an insurer may not "escape liability [through] . . . forced construction of the language in a policy” (Hooper) or "[technical constructions” (Pietrantonio). The construction of the owned-automobile exclusion is certainly a technical one, requiring the application of an obscurely drafted definition to an apparently unambiguous meaning of a commonly used English word.
In Hooper, the "forced construction” was merely whether the adjacent modifying terms applied to only "death” or both "homicide or death” in the phrase "shall not cover homicide or death resulting directly or indirectly from self-destruction” etc. In Pietrantonio, the technical phrase was " 'while the automobile is used in the business of demonstrating or testing.’ ” Clearly the owned-automobile exclusion is much more forced and technical [629]*629than either of these and the insurers should not escape liability.
5. Plainer or More Generous Use of Words
Rule 5 states "[t]he courts have no patience with attempts by a paid insurer to escape liability by taking advantage of an ambiguity, a hidden meaning, or a forced construction of the language in a policy, when all question might have been avoided by a more generous or plainer use of words.” (Emphasis added.) Hooper, supra at 393. Not to say there are not plainer and better ways of drafting the so-called owned-automobile exclusion, but the few suggested italicized words inserted below in the text of the instant insurers’ policies would go a long way toward putting the policy buyers and those dependent on the policy on notice:
(a) with respect to the owned automobile [as defined in the Deñnitions Section]
(1) the named insured and any resident of the same household,
(b) with respect to a non-owned automobile [as defined in the Deñnitions Section]
(1) the named insured,
(2) any relative ....
The failure of the drafters to be at least this open in their drafting demonstrates a clear disregard of Rule 5. In addition, clarity would seem to require that the owned-automobile exclusion should appear in the exclusions section in some form. In any particular policy these suggestions could prove insufficient and it would be necessary [630]*630to judge their substance and form to see whether they make clear the exclusion.
At this point it is informative, as noted by Justice Levin in his concurring opinion in Ruuska, to compare the lack of notice regarding the owned-vehicle exclusion with the notice required by the no-fault statute when a named person is excluded from liability coverage. The exclusion must be expressly "authorized by the insured,” and the following notice must appear, both on the face of the policy, the declaration page, or the certificate of the policy and on the required certificate of insurance carried by Michigan drivers:
"Warning — when a named excluded person operates a vehicle all liability coverage is void — no one is insured. Owners of the vehicle and others legally responsible for the acts of the named excluded person remain fully personally liable.” MCL 500.3009; MSA 24.13009.[6]
6. The Policyholder Protected Against Confusing Statements
Rule 6 originates from the DeLand case, which held that the insurance policy may not prominently make a promise of coverage and then less prominently attempt to contradict that promise in whole or in part in the body of the policy. DeLand found that doing so was "not only ambiguous but deceptive.”
In DeLand there was a prominent notice indicating a life insurance policy was noncancellable, but, in a later section entitled "Additional Provisions,” there was included a sentence stating that the acceptance of renewal premiums was optional. [631]*631This Court held the later clause invalid because it rendered the policy deceptive.
In the instant policies there is a promise of coverage in case of injury caused by an insured while driving an owned or nonowned automobile. In plain English this seems to cover everything. Later on in the definitions section in a complex sentence there is a limitation on the meaning of "nonowned” which limits the coverage afforded. In short, the DeLand Rule 6 seems to apply to the owned-automobile exclusion and render it invalid because it is deceptive and confusing.
SUBCONCLUSION
The owned-automobile exclusion appears to implicate all of the above six rules of construction gleaned from Michigan case law. The combined effect of these rules clearly invalidates the instant owned-automobile exclusions, and several of the individual rules as well would invalidate the instant owned-automobile exclusions.
E. THE RULE OF REASONABLE EXPECTATIONS
An adjunct to the rules of construction of insurance contracts is the rule of reasonable expectations.7
The rule was stated in Zurich Ins Co v Rombough, 384 Mich 228, 232-233; 180 NW2d 775 (1970), in which we quoted Justice Tobriner in the California case of Gray v Zurich Ins Co, 65 Cal 2d 263, 269-270; 54 Cal Rptr 104; 419 P2d 168 (1966), as follows:
[632]*632In interpreting an insurance policy we apply the general principle that doubts as to meaning must be resolved against the insurer and that any exception to the performance of the basic underlying obligation must be so stated as clearly to apprise the insured of its effect.
These principles of interpretation of insurance contracts have found new and vivid restatement in the doctrine of the adhesion contract. As this court has held, a contract entered into between two parties of unequal bargaining strength, expressed in the language of a standardized contract, written by the more powerful bargainer to meet its own needs, and offered to the weaker party on a "take it or leave it” basis carries some consequences that extend beyond orthodox implications. Obligations arising from such a contract inure not alone from the consensual transaction but from the relationship of the parties.
Although courts have long followed the basic precept that they would look to the words of the contract to find the meaning which the parties expected from them, they have also applied the doctrine of the adhesion contract to insurance policies, holding that in view of the disparate bargaining status of the parties we must ascertain that meaning of the contract which the insured would reasonably expect.
It is our opinion today that, in these cases, the policyholder, upon reading the contract language8 is led to a reasonable expectation of coverage.
The word "nonowned” is commonly understood to mean any car not owned by the subject. The [633]*633result of the difference between the common definition and the policy definition is that, while in common usage, every existing car is either owned or nonowned, in the policy language there is a significant group of cars that is neither owned nor nonowned. Rather than there being an affirmative statement of exclusion, there is an omission, contrary to the common interpretation of the broad statement of coverage of "the owned automobile or any nonowned automobile”9 To discover the omission, a person must refer to a separate section. Inasmuch as the excluded cars, i.e., cars owned by family members residing in the same household as the policyholder, are the ones most likely to be occasionally driven by the other insured family members, the owned-vehicle exclusion is the most significant exclusion in the liability coverage of the policies. If a policyholder refers to the section entitled "Exclusions,” a long list of exceptions to coverage will be discovered, but not a single word regarding the exclusion most likely to be invoked.
We believe that insured persons reading the liability provisions of these policies would reasonably expect liability coverage when driving the automobile insured by the policy and when driving other cars not owned by the insured. If the insurer intends to exclude such coverage when the insured person drives certain cars, it is simple enough to say so. As stated by Judge Learned Hand in Gaunt v John Hancock Mutual Life Ins Co, 160 F2d 599, 602 (CA 2, 1947), cert den 331 US 849 (1947):
[I]nsurers who seek to impose upon words of common speech an esoteric significance intelligible [634]*634only to their craft, must bear the burden" of any resulting confusion.
For all of the foregoing reasons, we would hold that an insurer may not, by artful definition of terms at variance with their commonly understood meanings, and by failure to speak plainly and clearly, effect an exclusion of coverage in an automobile liability policy.
F. THE QUESTION OF "STACKING”
In Deyarmond and Nicholson, the claimants are attempting to enlarge their residual liability coverage by "stacking” — obtaining coverage from more than one potentially applicable policy for the same accident. The insurers are attempting to employ the owned-vehicle exclusion as an antistacking clause, to prevent the aggregation of coverage.
Decisions regarding the validity of antistacking clauses in this state have varied as automobile insurance law has changed. In Horr v DAIIE, 379 Mich 562; 153 NW2d 655 (1967), this Court enforced an "other insurance” clause preventing stacking of two policies of uninsured motorist coverage. In Blakeslee v Farm Bureau Mutual Ins Co, 388 Mich 464; 201 NW2d 786 (1972), and Boettner v State Farm Mutual Ins Co, 388 Mich 482; 201 NW2d 795 (1972), this Court invalidated other-insurance clauses and owned-vehicle exclusions as antistacking devices for uninsured motorist coverage. These latter decisions were based on MCL 500.3010; MSA 24.13010, which required that uninsured motorist coverage be offered to all insureds covered for liability. That statute was effec[635]*635tive January 1, 1966, and was not at issue in Horr. In 1973, the no-fault statute was enacted and § 3010 was repealed. Subsequently, in Bradley v Mid-Century Ins Co, 409 Mich 1, 48; 294 NW2d 141 (1980), this Court stated that other-insurance clauses in uninsured motorist coverage are en- . forceable and benefits under such policies may not be stacked.
In reaching that conclusion, the Bradley Court stated that prevention of stacking of such coverage does not defeat an insured’s reasonable expectations. Id. at 57-59.
Assuming that antistacking clauses are similarly valid with regard to residual liability coverage, we note that the insurers in the cases we consider today do not claim that their policies contain other-insurance clauses, but instead rely on the owned-vehicle exclusion to prevent stacking in cases in which an insured is driving an automobile owned by a resident relative.10
Having held that the owned-vehicle exclusion employed in those policies is fatally ambiguous and invalid under the Michigan case law for construing insurance exclusions, we perceive no rationale which would lead us to conclude that the exclusion should nonetheless be held to be enforceable to the extent that it prevents stacking. Whether or not, before reading the policy, a policyholder had a reasonable expectation of the ability to stack coverage, upon reading the policies at issue in these cases, coverage would be expected.11
G. THE QUESTION OF THE EXCLUSION WITH REGARD TO UNINSURED MOTORIST COVERAGE.
facts: powers vDetroit automobile inter_INSURANCE EXCHANGE_
[636]*636On February 16, 1980, the plaintiff, Wanda Powers, was seriously injured while she was a passenger in an automobile owned by her sister, Donna Powers. Donna had been driving the car until it became disabled. She had then parked it on the shoulder of the road and had gone for help, leaving Wanda seated in the car. A van struck the parked automobile from the rear, throwing Wanda out of the car.
Neither the van’s owner nor its driver was insured. Donna Powers had not insured her automobile, and Wanda Powers had no insurance of her own.
The Powers sisters lived with their mother, Louise, who owned an automobile and had purchased a no-fault policy with the defendant, Detroit Automobile Inter-Insurance Exchange. The policy had optional uninsured motorist coverage for which Louise Powers had paid an extra premium. By the terms of the policy, Wanda was insured as a relative living in the same household as her mother.
The defendant paid personal protection insurance benefits, but denied payment of uninsured motorist benefits, due to the policy’s owned-automobile exclusion. Wanda Powers filed suit in Wayne Circuit Court and was granted summary judgment against defendant daiie. The Court of Appeals affirmed. This Court granted leave to appeal, 422 Mich 974 (1985).
DISCUSSION
The Powers case presents the issue of the validity of the owned-vehicle exclusion in a somewhat different context. In this case, the insurer is attempting to apply the exclusion to optional uninsured motorist coverage. The parties do not raise [637]*637the threshold issue of the validity, under the no-fault statute, of an exclusion of uninsured motorist coverage, and our analysis does not require us to reach that issue.12
The definitions of "owned automobile” and "non-owned automobile” in the Powers policy are the same in all significant respects as those in the Deyarmond policy quoted earlier. The definitions themselves were not contained in the uninsured motorist endorsement, but the following statement was contained in the definitions section of the endorsement:
"(b) the definitions of 'owned automobile’ and 'non-owned automobile’ in Section I [of the principal policy] apply to Uninsured Motorists coverage . . . .”
The Powers endorsement, however, did contain an "Exclusions” section which stated in pertinent part:
"The insurance afforded by this coverage does not apply:_
[638]*638"(1) to bodily injury to an insured sustained while occupying any automobile, other than an owned automobile, except a non-owned automobile to which there is applicable and available to such insured no insurance similar to that afforded by this coverage.”
Although, unlike the residual liability cases, the endorsement here does contain the above language in the exclusion section, the wording of the exclusion poses for the reader essentially the same problem as the statement of coverage poses in the residual liability cases. A policyholder would not expect that the terms owned and nonowned have contractual definitions at variance with their common meanings. Therefore, reading the exclusion and employing the common meanings,, the policyholder would understand the exclusion to apply to automobiles not owned by the insured that are covered by a policy that includes uninsured motorist coverage. By that interpretation the exclusion would operate as an antistacking clause. Wanda Powers’ injuries would not be excluded, because of the exception for injuries occurring while the insured is occupying "a non-owned automobile to which there is applicable and available ... no insurance similar to that afforded by this coverage,” and the car in which Wanda Powers was injured did not carry uninsured motorist coverage.
Therefore, under the rules of construction we derived from the Michigan case law, we would conclude that the insurer’s claimed exclusion was invalid, because of the technical definition of the, term "nonowned.” We recognize that subsection (b) of the definitions section of the endorsement quoted above states that "the definitions of 'owned automobile’ and 'nonowned automobile’ in Section I [of the main policy] apply to Uninsured Motorist Coverage.” However, we do not believe this refer[639]*639ence clarifies in the endorsement that which was not clear in the main policy. It does point out, however, that the drafters were not unacquainted with the reference device. How easy it would have been, and how much more significant and helpful, had the drafters referenced the definitions section and the definition of "nonowned automobile” in the persons insured section as discussed in part vi. It is there that the insured is led to believe that the insured is covered because that section says the insured is covered in both an owned and a nonowned automobile. If that section had specified a nonowned automobile (as defined in the definitions section), then the insurer would have had a better argument to sustain his technical construction.
In conclusion then, despite the differences in facts, the Powers case may be resolved under the analysis used in the residual liability cases discussed above, and we would hold, for the same reasons, that the nonowned-vehicle exclusion is void because it is unclear, ambiguous, and contrary to the policyholders’ reasonable expectations.
VII. ISSUE Hi: IF THE OWNED-AUTOMOBILE EXCLUSION IS VOID, IS THE STATUTORY MINIMUM OR THE CONTRACTUAL LIABILITY COVERAGE IN EFFECT?
The issue raised in Dennison and also in Nicholson is whether the statutory minimum liability coverage or the higher contractual liability coverage obtains, where liability occurs because an attempted exclusion from liability, the owned-automobile exclusion, is held invalid as not clear and properly drafted.
A. FACTS: DENNISON v WISNIEWSKI
On September 11, 1980, plaintiff, Robert Denni[640]*640son, was injured when the motorcycle on which he was a passenger was struck by an automobile driven by Myron Wisniewski and owned by Myron’s father, Mitchell Wisniewski. Dennison filed suit against the Wisniewskis, seeking damages for his injuries. Mitchell carried a policy with the Auto Club insuring the car involved in the accident, which provided for residual liability coverage of $20,000 per person and $40,000 per incident. Myron had a policy on another vehicle which he owned, which provided for residual liability coverage of $50,000 per person and $100,000 per incident. Both policies had owned-automobile exclusions. The insurer and insured parties, relying on the result in State Farm v Ruuska, 412 Mich 321; 314 NW2d 184 (1982), agreed that the policies were both applicable and could therefore be stacked. The injured plaintiff filed a garnishment action to determine the amount of coverage. Plaintiff argued that the policy limit of $50,000 was payable from Myron Wisniewski’s policy. Garnishee defendant Auto Club claimed that, because "the coverage that was being afforded . . . was by operation of law (i.e., Ruuska’s invalidation of the exclusionary clause) and contrary to the express terms of the contract, no more coverage was afforded than the minimum liability” coverage required by law. The trial court granted summary judgment for Auto Club. In an unpublished opinion, the Court of Appeals reversed. We granted leave to appeal, 424 Mich 879 (1986).
B. ANALYSIS
In these cases, the insurers argue that the applicable limit of the liability policies at issue should be the minimum coverage of $20,000 per person and $40,000 per incident required by law, MCL [641]*641500.3131; MSA 24.13131, MCL 500.3009; MSA 24.13009, rather than the $50,000/$100,000 limits of coverage contained in the policies. The argument is based on our opinion in State Farm Mutual Automobile Ins Co v Shelly, 394 Mich 448; 231 NW2d 641 (1975), in which we held that, where an exclusionary clause in an automobile liability insurance policy was held to be void under the Motor Vehicle Accident Claims Act (mvaca), the reinstated coverage would be the minimum required by law rather than the amount stated in the policy.
The claimant argues that the removal of one invalid clause (the owned-vehicle exclusion) from the policy should not cause the reformation of another, unrelated, clause. Claimant also argues that the application of Shelly to this situation would defeat the policyholder’s reasonable expectations, and that the Shelly doctrine should be abandoned.
In Shelly, an automobile liability policy expressly excluded coverage of the insured vehicle when the family’s son was driving. The son drove the car, resulting in death and serious injury to several persons. That exclusion was held to be void as against the policy of the mvaca. Therefore, Shelly may be cited for the proposition that where a clearly expressed exclusion is found to be invalid under a controlling statute, the reinstated coverage shall be the minimum required by law. Such is not the case here.
In Dennison, and in Nicholson as well, the owned-automobile exclusion is invalidated, not because the no-fault act requires its invalidation, but because the insurer did not draft the exclusion in a clear and understandable fashion. As set forth in issue i (part v) of this opinion, the no-fault act [642]*642permits this type of exclusion. This result is also authorized in Ruuska by the combination of Justice Coleman’s three-vote opinion and Justice Levin’s one-vote opinion. The owned-automobile exclusion in Dennison and Nicholson is invalidated by its improper drafting as set forth in issue ii (part vi) of this opinion.
The rationale of the Shelly opinion is that, where a clearly worded exclusion in an insurance contract is void as contrary to the statutory policy, the statute controls both as to the exclusion and the amount of liability coverage. Since the rationale of the invalidation of the exclusion in the instant cases is improper drafting, the insurance contract is reformed only to the extent of the impropriety which affects the exclusion, but not the liability coverage. The result, therefore, is that in Dennison and Nicholson, the liability coverage is that contracted and paid for, rather than the statutory minimum.
CONCLUSION
We would hold today that a no-fault insurer may exclude coverage for residual liability when an insured is driving a vehicle owned by a resident family member, so long as the exclusion is clearly and unambiguously stated. In Schiebout, Deyarmond, and Nicholson, the exclusion was not clearly stated and is therefore void. In Powers, a similar exclusion in optional uninsured motorist coverage is void for the same reason. In Dennison, the applicable limit of residual liability coverage is the $50,000 provided by the policy.
We would affirm the decisions of the Court of Appeals in Powers, Schiebout, and Dennison, and reverse the decisions in Deyarmond and Nicholson.
Archer, J., concurred with Williams, C.J.
[643]*643Brickley and Cavanagh, JJ., concurred in the result only.