Clausen Miller Appellate Team Wins Anti-stacking Case in Seventh Circuit
Clausen Miller Appellate & Trial Monitoring Practice Group attorneys were recently successful in securing a favorable judgment for an insurer in an automobile insurance “stacking” case in the United States Court of Appeals for the Seventh Circuit.
The case involved the issue of whether the insureds were entitled to “stack” the insurance limits for underinsured motorist and medical expense coverage under primary and excess policies based on the number of vehicles insured. The primary auto policy provided $500,000 in underinsured coverage per vehicle and $100,000 per insured person for medical expenses. However, based on the policy’s coverage for five vehicles and the configuration of information on the declarations pages, the insureds claimed they were entitled to $2.5 million in underinsured coverage and $300,000 for medical expenses. The umbrella policy provided $1 million in underinsured coverage, and the insureds claimed they were entitled to stacked limits of $5 million.
The Seventh Circuit rejected the plaintiffs’ arguments and held coverage to the single vehicle limit for both the primary and excess policies and to the single insured limit for medical expenses. Clausen Miller partner Don Sampen argued the case, and Clausen Miller Appellate & Trial Monitoring Practice Group Chair Melinda Kollross and partner Mike Raudebaugh participated on the briefing. Saslow v. Bankers Standard Insurance, 2026 U.S. App. Lexis 15297 (7th Cir. May 28, 2026).
Melinda S. Kollross
Don R. Sampen
Michael J. Raudebaugh