In June of 2013, Kaysha Bell was killed in a one-vehicle car accident. The vehicle was insured through a policy from Geico Indemnity Company (“Geico”). The policy included uninsured-motorist coverage. Bell’s mother, Sharon Bell, was named as the administratrix of Kaysha Bell’s estate. On behalf of the estate, Bell’s mother sued Geico, as well as the uninsured driver, for damages. After the case proceeded to trial, the trial court entered a judgment in favor of the estate for $1,000,000. The trial court noted in its judgment that the insurance policy “provided uninsured motorist coverage in accordance with the policies [(sic)] definition of ‘uninsured auto.’” Following trial, Geico appealed on the basis that the trial court improperly construed the policy to require it to pay UIM benefits to the estate.  

On appeal, the estate argued that the vehicle, which was named on the declarations page of the policy and for which Kaysha Bell had paid a premium for bodily-injury-liability coverage, was converted to an “uninsured auto” because of the language used in the definition of “insured auto” in the UIM-coverage section of the policy. Specifically, the estate argued that an “insured auto” must be both the automobile described in the declarations page of the policy and “must be covered by the bodily injury liability coverage of the policy.” Further, because the policy excluded liability coverage for Bell’s death under the household exclusion in the liability section of the policy, the estate contended that the vehicle was not actually covered by the bodily-injury-liability provisions of the policy. Geico argued that the vehicle was an “insured auto” under the policy because it was “described in the declarations and covered by the bodily-injury-liability coverage of the policy.” Thus, Geico argued that the vehicle could not be both an insured auto and an uninsured auto under the same policy.  Geico argued that the term “insured auto” does not become ambiguous simply because the application the household exclusion precluded coverage for Bell’s death.  

The Alabama Court of Civil Appeals found the estate’s construction of the policy “strained and unreasonable.” Citing decisions from the Alabama Supreme Court discussing that UIM policies “deal with the motor vehicle which is uninsured, not the motorist,” the court held that “an insurer’s denial of liability coverage to an individual because of an applicable liability exclusion or exclusionary definition does not trigger the availability of uninsured motorist coverage to that individual under the same policy.” Further, the Court noted, “The construction of the policy urged by the estate and adopted by the trial court swallows the household exclusion and improperly defeats an express provision in the policy…” Accordingly, the Court reversed the judgment of the trial court and remanded the case with instructions for the trial court to enter a judgment in favor of Geico.