Koken v. Reliance Ins. Co

In Koken v. Reliance Ins. Co., 586 Pa. 269, 287-88, 893 A.2d 70, 80-81 (2006) (Reliance), our Supreme Court noted that Article V follows from a model act of the National Association of Insurance Commissioners (NAIC), which, in turn, was based on a 1967 Wisconsin law. Based on this history, the Supreme Court looked to the Wisconsin legislature's comments as an aid in interpreting a provision in Article V, reasoning: "What is more helpful is a consideration of the Wisconsin legislature's comment in adopting what is, in essence, the blueprint for the Pennsylvania statute." Reliance, 586 Pa. at 292-93, 893 A.2d at 84.