Mid-Century Insurance Co. of Texas v. Kidd

These two cases present a common question: can an insured recover the same loss under both the uninsured/underin-sured motorist (UM/UIM) and personal injury protections (PIP) of a standard automobile insurance policy? Two courts of appeals answered yes and refused to enforce a policy provision barring duplication of UM and PIP benefits that would result in double recovery. 1 We hold that a non-duplication-of-PIP-benefits provision in an automobile insurance policy is valid and enforceable. Accordingly, we reverse the judgments of the courts of appeals and remand these cases to their…