Court Affirms Trial Court's Judgment Finding Driver Not Entitled to UIM Benefits
Beeman v. ACCC Insurance Company
In January 2017, Lester Beeman (“Beeman”) was injured in a two-car accident while driving a car insured under a policy of insurance purchased by Renada Reese (“Reese”) from ACCC Insurance Company (“the insurer”). The driver of the other vehicle involved was uninsured. Beeman sued the uninsured driver in the Montgomery Circuit Court ("the trial court"), asserting, among other things, claims for negligence and wantonness. Beeman amended his complaint to seek an award of uninsured-motorist ("UIM") benefits from the insurer. The insurer moved to dismiss Beeman's claim against it pursuant to Rule 12(b)(6), Ala. R. Civ. P., because Reese was the "named insured" in the policy and she had rejected UIM coverage, as permitted by Ala. Code 1975, 32-7-23(a). The trial court granted the insurer's motion and dismissed all claims against it. Beeman argued on appeal that he was a "named insured" on the policy and that, therefore, Reese's rejection of UIM coverage was not binding on him.
The issue before the Court of Civil Appeals was whether Beeman was a “named insured” for purposes of UIM benefits such that Reese’s rejection of UIM coverage was effective as to Beeman. Beeman argued that because he was a named “driver” on the policy declarations page and that because he was Reese’s son and living in her house, he fell within the “named insured” definition of the policy. Therefore, because he did not reject the UIM coverage himself, he was entitled to the benefits.
The Court found that only Reese was listed on the initial insurance application and the renewal certificate as the “policyholder”. The Court noted that the term “policyholder” is equivalent to “named insured.” Thus, the Court held that Beeman was not a named insured under the policy, and therefore, Reese’s rejection of UIM coverage was effective as to Beeman. Therefore, the Court of Civil Appeals affirmed the judgment of the trial court dismissing Beeman’s claims against the insurer.
