Wright v. United Services

CourtColorado Court of Appeals
DecidedAugust 21, 2025
Docket24CA1373
StatusUnpublished

This text of Wright v. United Services (Wright v. United Services) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wright v. United Services, (Colo. Ct. App. 2025).

Opinion

24CA1373 Wright v United Services 08-21-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA1373 El Paso County District Court No. 23CV31825 Honorable David Shakes, Judge

Bruce M. Wright,

Plaintiff-Appellee,

v.

United States Services Automobile Association, a/k/a USAA, a Texas corporation and a Colorado authorized insurance company,

Defendant-Appellant.

JUDGMENT REVERSED AND CASE REMANDED WITH DIRECTIONS

Division I Opinion by JUDGE MOULTRIE J. Jones and Kuhn, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced August 21, 2025

J. Gregory Walta, Colorado Springs, Colorado, for Plaintiff-Appellee

Spencer Fane LLP, Jeremy A. Moseley, Hannah S. McCalla, Denver, Colorado, for Defendant-Appellant ¶1 Defendant, United Services Automobile Association (USAA),

appeals the judgment entered in favor of plaintiff, Bruce M. Wright.

We reverse and remand the case to the district court.

I. Background

¶2 In May 2023, an underinsured motorist hit and seriously

injured Wright while he was riding his bicycle. Wright was insured

at the time of the accident, having maintained automobile

insurance through USAA for decades. From at least 2002 until

Wright’s accident in 2023, Wright’s policy included uninsured

motorist and underinsured motorist coverage (UM/UIM coverage)

and bodily injury coverage (BI coverage). His policy included BI

coverage in the amount of $300,000 per person and $500,000 per

accident ($300,000/$500,000).

¶3 Wright’s injury-related expenses exceeded the underinsured

driver’s BI coverage policy limits, so Wright sought to use his own

UM/UIM coverage, which he believed to be equal to his BI coverage

at the time of the accident: $300,000/$500,000.

¶4 Shortly after the accident, Wright informed USAA that he had

been injured by an underinsured driver and that his injuries totaled

more than the $300,000/$500,000 of UM/UIM coverage provided

1 by his policy. Wright asserted that he was entitled to

$300,000/$500,000 of UM/UIM coverage based on a 2008 policy

notice he received saying his UM/UIM coverage limits would equal

his BI coverage limits unless he returned to USAA a

“Rejection/Selection Form” (rejection/selection form) rejecting the

UM/UIM coverage limits, which he didn’t do.

¶5 USAA rejected Wright’s assertion that his UM/UIM coverage

limits were $300,000/$500,000. Instead, USAA told Wright his

UM/UIM coverage limits were $25,000 per person and $50,000 per

accident ($25,000/$50,000) and had been since at least 2002.

¶6 Wright filed a complaint against USAA in district court that, as

relevant here, asserted a claim for declaratory judgment. Wright

asked the court to declare that he was entitled to UM/UIM coverage

in the amount of $300,000/$500,000 because (1) USAA’s 2008

notice was defective under section 10-4-609, C.R.S. 2024; “and/or”

(2) he chose UM/UIM coverage of $300,000/$500,000 by not

“completing, signing[,] and returning the [rejection/selection form].”

¶7 Wright filed a motion (the motion) in support of his request for

declaratory judgment. Included as an exhibit to the motion was a

form from Wright’s 2008 policy renewal documents generally

2 explaining what UM/UIM coverage entails (2008 summary

disclosure form). The 2008 summary disclosure form included the

following language (the increased coverage language):

Uninsured Motorists (UM) Coverage:

....

Is issued with UM Coverage limits equal to your BI [coverage] limits unless you reject UM Coverage or select lower UM Coverage limits by completing, signing, and returning the Rejection/Selection Form by mail or at usaa.com.

As he alleged in his complaint, Wright argued that the increased

coverage language was an offer from USAA for UM/UIM coverage

equal to his BI coverage limits that he accepted by not completing

the rejection/selection form.

¶8 He also argued that because section 10-4-609(2) required

USAA to notify him of his coverage options in a manner reasonably

calculated to enable him to make an informed decision about

whether to obtain UM/UIM coverage limits equal to his BI coverage

limits, any ambiguities resulting from the increased coverage

language should be resolved in his favor to require reformation of

the terms of his policy.

3 ¶9 For purposes of Wright’s request for declaratory judgment,

USAA didn’t dispute that Wright was injured by an underinsured

driver or that he had maintained a policy with UM/UIM coverage for

decades. However, in its response to the motion, USAA argued that

Wright’s references to his insurance policy documents were

incomplete. USAA submitted to the court Wright’s complete

automobile policy packets for the years 2002, 2008, 2014, 2020,

2022, and 2023 (collectively, the policy packets). USAA argued that

(1) the plain language of the policies limited Wright’s UM/UIM

coverage to $25,000/$50,000, and (2) it had complied with section

10-4-609(2) by offering Wright higher UM/UIM coverage, as

demonstrated in the policy packets, so reformation of the 2008

policy or any subsequent policies was precluded. USAA also noted

that Wright’s $25,000/$50,000 UM/UIM coverage limit had

remained in place, unchanged through every renewal period since

2002, despite USAA’s repeated notice to Wright that higher coverage

limits were available. USAA asked the court to deny Wright’s

request for declaratory judgment.

¶ 10 The court treated the motion as a C.R.C.P. 56(h) motion for a

determination of a question of law and granted it.

4 ¶ 11 In its ruling, the court relied on Shelter Mutual Insurance Co. v.

Mid-Century Insurance Co., 246 P.3d 651 (Colo. 2011), for its

analysis of an insurer’s responsibility to adequately notify a

policyholder of a reduction in coverage during the policy renewal

period. The court also relied on Bailey v. Lincoln General Insurance

Co., 255 P.3d 1039 (Colo. 2011), for guidance in interpreting

exclusionary language1 in insurance contracts and applying the

doctrine of reasonable expectations.

¶ 12 The court reasoned as follows:

• While the issue in this case “[was] not precisely a renewal

reduction situation,” it found the analysis and legal

principles in Shelter and Bailey persuasive.

• Shelter and Bailey advise that insurance policy renewal

contracts are subject to heightened scrutiny and the

doctrine of “reasonable expectations,” which requires

insurers to adequately relay to policyholders any

coverage-limiting provisions.

1 “An exclusion” is a provision of an insurance policy “that excepts

certain events or conditions from coverage. Dupre v. Allstate Ins. Co., 62 P.3d 1024, 1029 (Colo. App. 2002).

5 • The reasonable expectations doctrine has two prongs:

first, whether an ordinary, objectively reasonable person

would fail to understand that he is not entitled to the

coverage at issue based on the language of the policy and

second, whether, because of circumstances attributable

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