The Indiana Court of Appeals has ruled in favor of Brittney Best in her claim for underinsured motorist (UIM) benefits following the tragic death of her 17-year-old son, Jaxson Schooley, in a car accident. The court's decision, issued on September 11, 2026, clarifies how UIM benefits are calculated when multiple parties are involved in a wrongful death claim. This ruling could significantly impact how insurance claims are handled in similar cases across Indiana.
The case arose after Jaxson was killed in a head-on collision caused by another driver in August 2023. Following the accident, the driver’s insurance company, State Farm, paid a total of $100,000, split equally between Best and Jaxson's father, Jeffrey Schooley. However, both Best and Schooley had their own insurance policies that included UIM coverage, which they believed should provide additional compensation due to the insufficient payment from the tortfeasor's insurance.
Best filed claims against The Standard Fire Insurance Company d/b/a Travelers Insurance and CSAA General Insurance Company d/b/a AAA Insurance for the remaining UIM benefits, arguing that the amount she received from State Farm was less than the UIM limits of her policies. Both insurance companies denied her claims, leading Best to file a lawsuit seeking $50,000 from each insurer. The trial court dismissed her complaint, stating that the total amount paid by State Farm meant the tortfeasor was not underinsured.
The court ruled that the relevant comparison for determining whether the tortfeasor's vehicle was underinsured should focus on the amount Best personally received from State Farm, rather than the total amount paid to both parents. The court cited Indiana's UIM statute, which defines an underinsured motor vehicle based on the limits of coverage available for payment to the insured.
Judge Vaidik, who authored the opinion, stated, "the dispositive amount for purposes of determining whether the tortfeasor’s car was underinsured is $50,000—the amount that Best, the claimant, recovered from State Farm, the tortfeasor’s liability insurer." The court emphasized that Best's interpretation of the law was correct and aligned with previous rulings by the Indiana Supreme Court.
The court's ruling reverses the trial court's dismissal of Best's complaint and remands the case for further proceedings. Specifically, the court ordered the lower court to enter partial summary judgment for Best, confirming her entitlement to $50,000 in UIM benefits. The court also directed the trial court to determine how the payment would be allocated between the two insurers.
This ruling has significant implications for other claimants in similar situations. It clarifies that when multiple parties are involved in a wrongful death claim, the amount received by each claimant is critical in determining eligibility for UIM benefits. This could lead to more claimants successfully obtaining additional compensation from their UIM policies, even when the total amount paid by the tortfeasor's insurer meets the policy limits.
Moreover, the decision reinforces the idea that UIM coverage is intended to protect individuals from insufficient payments following accidents caused by underinsured motorists. This case may set a precedent for future claims involving multiple insured parties and could influence how insurance companies approach UIM claims in Indiana.
Looking ahead, it remains to be seen whether Travelers or AAA will seek to appeal the ruling. The court did not address how liability would be apportioned between the two insurers, leaving that question for the trial court on remand. As of now, Best is entitled to pursue her claim for UIM benefits, and the outcome could affect many families dealing with similar tragic circumstances.