Jonesv.Ga. Farm Bureau Mut. Ins. Co.
After Ernie Jones died in a car crash, his children challenged Georgia Farm Bureau’s determination that his policy provided $25,000 in uninsured-motorist coverage rather than the $1 million liability limit. In 2015, Jones signed a form affirmatively choosing UM limits lower than his liability limits, but the form did not state the amount; the policy incorporated a declarations page listing $25,000 UM coverage. The Court of Appeals held that the statute does not require an insured’s choice of lower UM limits to be written or to specify the amount on the same document. Jones’s signed election, read with the declarations page incorporated into his policy, established the $25,000 limit and satisfied the insurer’s burden. The documents resolved the issue, so the agent’s credibility did not matter. The discarded quote sheet did not support spoliation because it was discarded before the accident and before litigation was pending or reasonably contemplated. The court also rejected the children’s remaining arguments and affirmed partial summary judgment for the insurer in both appeals.
Loading published copy…

