Whether a multiple vehicle accident creates separate occurrences, thereby increasing policy limits, was the issue in Auto-Owners Ins. Co. v. Munroe, 2010 U.S. Dist. LEXIS 15062 (7th Cir. July 22, 2010).

   Three trucks owned by Wayne Wilkins Trucking were traveling the highway in convoy.  All trucks were covered under a single policy issued by Auto-Owners.  The policy stated that the maximum total coverage was $1,000,000 regardless of how many vehicles were involved in an accident.

   Munroe sustained significant injuries when the three trucks collided.  Munroe sued the two other drivers for negligence and Wilkins for negligent hiring and training.  A partial settlement was reached whereby Munroe released Wilkins and the other drivers from any liability above their insurance coverage in exchange for $903,449, the remainder of the $1,000,000 coverage limit after property damage was paid to the owner of Munroe's truck.  The agreement stated Auto-Owners would seek a declaratory judgment that liability coverage was limited to $1,000,000.  Munroe reserved the right to proceed with his case if it was determined the policy limits exceeded $1,000,000.

   In Auto-Owners' declaratory judgment action against Munroe, the district court held the policy limited coverage to $1,000,000 for each occurrence.

   On appeal, Munroe argued the policy limit was $3,000,000 because there were three occurrences based on the separate negligent acts of each defendant.  The Seventh Circuit disagreed.  The policy clearly provided up to $1,000,000 of coverage per occurrence for each insured vehicle.  The only question was whether there was more than one occurrence.

   This case involved a single force and an uninterrupted chain reaction involving several vehicles, and thus a single continuous occurrence.   A single claim or injury did not give rise to multiple occurrences merely because several acts of negligence combined to produce a single result.  Because there was a single occurrence, the policy limited coverage to $1,000,000.