Virginia Farm Bureau Mutual Insurance v. Hodges

This case involves the interpretation of a medical payment provision contained in three automobile insurance policies. The provision in question limits the insurance company’s liability to the payment of “all reasonable expenses incurred within one year from the date of accident for necessary medical . . . services.” We decide whether certain anticipated medical expenses were “incurred” within one year of the accident.

Lisa Michelle Hodges injured her right arm in an automobile accident on June 14, 1986. Virginia Farm Bureau Mutual Insurance Company (the insurance company) provided medical…