American Family Mutual Insurance Company and American Standard Insurance Company of Wisconsin Missouri Cases

Roger Kitchen and Lori Kissinger, divorced parents of Megan Kitchen who died in a car accident, sought underinsured motorist (UIM) and medical expense coverage from their respective insurance policies. The trial court issued a declaratory judgment regarding the stacking and reduction of these coverages under Illinois law for Kitchen's policies and Missouri law for Kissinger's policies. The appellate court affirmed the trial court's findings for Kitchen's Illinois policies, concluding that UIM and medical expense coverages do not stack and UIM coverage is reduced by the full liability payment. For Kissinger's Missouri policies, the court reversed the finding that UIM coverage stacks, but affirmed that medical expense coverage stacks and UIM coverage is not reduced by the liability payment.