Michigan Court of Appeals; Docket No. 76580; Published
Judges Danhof, T. M. Burns, and Bell; Unanimous; Per Curiam
Official Michigan Reporter Citation: 142 Mich App 108; Link to Opinion 
STATUTORY INDEXING:
Scope of Mandated Coverages [§3131(1)]
Liability Exclusions Prohibiting Stacking of Coverages [§3131]
TOPICAL INDEXING:
Not Applicable
CASE SUMMARY:
In this unanimous per curiam Opinion, the Court of Appeals affirmed the validity of an "anti-stacking" provision in ACIA's "master member" policy which prohibited the stacking of liability limits of the five automobiles insured under the master member policy. The court relied on the Supreme Court's opinion in Bradley v Mid-Century (Item No. 312), which declared that policies issued after October 1,1973 may include enforceable "other insurance" clauses which prohibit stacking.
Second, the Court of Appeals reversed the trial court's ruling that the parental loss of consortium claim filed by Lanyon's minor daughter was to be treated as a separate injury and thus covered under a separate limit of liability. In reversing the trial court on this point, the court relied upon specific language in the insurance policy which stated that the individual limit of insurer liability for each person includes all claims for derivative damages (i.e., loss of consortium) arising out of injury to that person.
