Macedo v. Automobile Insurance Co.

Summary

The court held that the phrase "motor vehicle liability coverage" in CJP § 5-806(b) refers to mandatory coverage under a primary motor vehicle liability policy, not excess coverage under a personal umbrella policy. Although the statutory language is ambiguous when read in context, the Insurance Article, legislative history, and consequences of the competing interpretations show that the statute was intended to equalize coverage for family members under primary automobile policies. The court therefore upheld the umbrella policy's household exclusion and affirmed summary judgment for the insurer.