Evidence of Policy Limits Admitted at Trial
State Farm Mutual Automobile Ins. Co. v. Kimberly S. Earl and the Estate of Jerry Earl, __ N.E.2d __, 2015 WL 3608850 (Ind. June 9, 2015) (Massa, J.)
Jerry Earl filed a claim against State Farm Mutual Automobile Ins. Co. (hereinafter “Defendant”) seeking uninsured motorist benefits following a motorcycle accident that resulted in serious injuries. Before trial, Defendant moved to exclude any evidence of the uninsured motorist policy limits. The motion was denied. During trial, Plaintiff’s counsel referenced the policy limit of $250,000.00 multiple times. The jury found in favor of Plaintiff and awarded the estate $175,000.00 and Plaintiff $75,000.00, for a total judgment of $250,000.00. Defendant appealed and a divided Court of Appeals panel reversed and remanded the claim holding that the coverage limit was irrelevant and inadmissible. Plaintiff filed a Petition to Transfer which was granted by the Supreme Court of Indiana.
The Court considered whether the trial court abused its discretion by allowing evidence of the policy limit into evidence and, if so, whether the error was clearly prejudicial. The Court noted that the rule generally prohibiting the admissibility of evidence of liability insurance was not applicable here as liability was not contested. Ultimately, it held that the trial court did not abuse its discretion in admitting the policy limits into evidence as it may have provided the jury with helpful information regarding the relationship of the parties and regarding the lawsuit. However, the Court acknowledged that the probative value of this evidence was low, but that it was not substantially outweighed by the prejudicial effect.