Lehrhoff v. Aetna Cas. and Sur. Co

In Lehrhoff v. Aetna Cas. and Sur. Co., 271 N.J. Super. 340, 638 A.2d 889 (App.Div.1994), the Court held that the reasonable expectations provided by the declaration page "cannot be contradicted by the policy's boilerplate unless the declaration page itself clearly so warns the insured." The Court stated: A personal automobile insurance policy is a bulky document, arcane and abstruse in the extreme to the uninitiated, unversed and, therefore, typical policyholder. We are persuaded, therefore, that a conscientious policyholder, upon receiving the policy, would likely examine the declaration page to assure himself that the coverages and their amounts, the identity of the insured vehicle, and the other basic information appearing thereon are accurate and in accord with his understanding of what he is purchasing. We deem it unlikely that once having done so, the average automobile policyholder would then undertake to attempt to analyze the entire policy in order to penetrate its layers of cross-referenced, qualified, and requalified meanings. Id at 346-47, 638 A.2d 889.