Rago v. State Farm Mutual Automobile Insurance

BECK, Judge:

We are today presented with an issue of first impression: to what extent must a parent rely on the financial support and uncompensated services provided by a child in order to be a “dependent” for purposes of receiving survivor’s benefits under the Pennsylvania No-fault Motor Vehicle Insurance Act (No-fault Act). 1

Consistent with the remedial nature of the No-fault Act, we hold that a claimant must demonstrate on the record an actual dependency but need not show such complete reliance that any finding of independence would negate the finding of dependency. The test is whether the…