State Farm Mutual Automobile Insurance Company, Petitioner/cross-Respondent v. Larry Houle, Sunnie Houle, Graham…

Summary

The court held that the families' emotional-distress claims did not trigger separate per-person UIM coverage because the family members were not occupants, pedestrians, or witnesses to the collision and therefore were not injured "in" the same accident as the deceased and injured children. It also held that the disputed policies complied with Alaska's UIM statutes, so reformation was unnecessary; because the applicable per-person limits had been exhausted, the court did not decide whether loss-of-consortium claims were otherwise covered. The court reversed the reformation order and remanded for entry of judgment for State Farm.