State Farm Mut. Auto. INS. Co. v. Houle

Summary

The court held that the family members' emotional-distress claims did not trigger separate per-person UIM coverage because they were not occupants or pedestrians in, and did not witness, the collision. It further held that Alaska's UIM statutes use the same ordinary meaning of coverage for injuries suffered "in one accident" and therefore did not require broader coverage or reformation of the policies. The court reversed the reformation order and remanded for entry of judgment for State Farm.