In Progressive Northwest Insurance Co. v. Lautenschlager, 488 P.3d 509 (Idaho 2021), the Idaho Supreme Court considered whether a “combined single limit” automobile policy satisfied the State’s Financial Responsibility Act. The Court noted that the insurer’s maximum liability under the motorcycle liability policy was $500,000, given the fact that the policy had a combined single liability limit of $500,000. The Court found that the plain and ordinary meaning of the term “combined single limit” meant that the various coverages under the policy were united into one number bounded by the utmost agreed upon coverage limit. As such, the policy unambiguously provided a maximum of $500,000 in liability coverage for any one accident, regardless of the claims and types of coverage involved, including underinsured motorist coverage.
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