Smalls v. State Farm Mutual Automobile Insurance

TERRY, Associate Judge:

These cross-appeals present us with an issue of first impression: whether a “household exclusion” clause contained in an automobile insurance policy is invalid because it violates a statutory requirement that owners of automobiles in the District of Columbia carry third-party liability insurance. We are also faced with a less complex issue of whether the household exclusion clause in this particular case was subject to the doctrine of reasonable expectations. The trial court held that the household exclusion clause was invalid, but only to the extent that it conflicted…