Allison Chase v. Horace Mann Insurance Company, Respondent

Summary

The court held that changing the sole named insured from Richard Chase to Allison Chase created a new policy for purposes of Florida's uninsured-motorist statute because Allison had never previously had the opportunity to waive or reduce UM coverage. Because Allison never signed a written waiver, Horace Mann was required to provide UM benefits equal to the policy's bodily-injury liability limits, and Richard's prior waivers did not bind her or her father's estate under her policy. Justice Polston, joined by Justice Canady, dissented on jurisdictional grounds, concluding that express and direct conflict was not apparent from the face of the district court's decision.