Whelan v. State Farm Mut. Auto. Ins. Co.

Summary

The Court held that a UM/UIM policy provision barring suit six years after the accident is unreasonable and unenforceable because it may expire before the insured's claim accrues. It also held that judicial reformation under the governing UM/UIM framework does not apply to policies issued before May 20, 2004, when the relevant rejection requirements were first announced. The Court therefore reversed and remanded for judgment enforcing the policy's facial rejection of UM/UIM coverage.