Pro-Medics Therapy & Rehab Center LLC a/a/o Isel Suarez v. United Automobile Insurance Company
A PIP provider, as assignee, sued United Auto for benefits for a person listed on the policy declarations page as "co-insured" but who was not a resident relative of the named insured (they were listed as spouses but were in fact married to others). The trial court granted United Auto summary judgment finding no coverage. The Third DCA reversed, holding that because "co-insured" was undefined in the policy, its plain meaning — a person together with the insured who is covered by the policy — entitled her to coverage, as did the policy's own definition of "named insured" as a person named in the declarations.
Key facts
- Pro-Medics Therapy & Rehab Center LLC, as assignee of Isel Suarez, sued United Automobile Insurance Company for PIP benefits for a person listed as 'co-insured' on the policy's declarations page.
- The person listed as 'co-insured' was not a resident relative of the named insured, as the parties were listed as spouses but were actually married to other people.
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Why it matters
Useful authority for first-party and PIP claimants when an insurer contests the status of a person named on the declarations page under a label like "co-insured" that the policy leaves undefined. The court's… — full analysis with a trial
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