Commercial Union Midwest Insurance v. Vorbeck

¶ 1. In Badger Mutual Insurance Co. v. Schmitz, 2002 WI 98, ¶ 75, 255 Wis. 2d 61, 647 N.W.2d 223, the supreme court considered whether an underinsurance reducing clause in a motor vehicle *208insurance policy was ambiguous, thereby rendering the underinsured motorist (UIM) coverage illusory. As part of the analysis, the Schmitz court said, "[R] educing clauses must be crystal clear in the context of the whole policy. Otherwise, insureds are not likely to understand what they are purchasing." Id., ¶ 46. Following Schmitz, the court of appeals issued a number of opinions applying the Schmitz…