Karabin v. State Auto. Mut. Ins. Co.

10 Ohio St.3d 163, 462 N.E.2d 403 (1984)

Karabin, a pedestrian on a sidewalk, was severely injured by an uninsured driver. Karabin had two car insurance policies from State Auto, and each policy provided uninsured motorist coverage in the amount of $50,000. Both policies also contained an anti-stacking provision stating that State Auto’s maximum liability under both the policies shall not exceed the highest applicable limit under any one policy.

The insurance company argued that this “anti-stacking” provision prevents an insured from “stacking” the coverages of each policy so that, in this case, Karabin had $100,000 available to compensate him for his injuries. State Auto honored Karabin’s claims under one policy, but refused to honor claims under both.

Karabin sued State Auto and the Supreme Court of Ohio found that the anti-stacking provision was valid and Karabin’s recovery under his insurance policies was thereby limited to one. Thus, even though he paid a separate premium for both coverages, the coverage on the second policy confers absolutely no additional benefit to him.