In Erie Ins. Exch. v. Mione, the Pennsylvania Superior Court revisited the issue of underinsured motorist coverage (UIM). Here, the Court affirmed the lower court’s order granting the insurance company’s motion for judgment on the pleadings. The Court reviewed recent holdings regarding UIM, household exclusions, and stacking in Erie Ins. Exch. v. Petrie, 242 A.3d 915 (Pa. Super. Ct. 2020), and Erie Ins. Exch. v. King, 246 A.3d 332 (Pa. Super. Ct. 2021). The Court ruled that the vehicle at issue was covered under a Progressive policy that did not include UIM coverage so there was no policy on which to stack the Erie policy. Perhaps funny: In a lengthy, single-spaced footnote, the Court requested that “the trial court to please not provide the background and rationale for its decision in lengthy, single-spaced footnotes to its order.”
