Allison Chase v. Horace Mann Insurance Company, Respondent

Summary

The Court held that changing the sole named insured on an automobile policy for the first time creates a new policy for purposes of Florida's uninsured-motorist statute, even when the policy retains the same bodily-injury liability limits. Because Allison Chase never received the required opportunity to reject or reduce uninsured-motorist coverage in writing, her father's prior waiver did not bind her or her father's estate, and she was entitled to coverage equal to the policy's liability limits. 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.