Wilder v. Aetna Life & Casualty Ins. Co

In Wilder v. Aetna Life & Casualty Ins. Co., 140 Vt. 16, 433 A.2d 309 (1981), plaintiff had been in an automobile accident with defendant's insured and sued the insurer under VCFA claiming it had failed to pay plaintiff pursuant to a settlement agreement. The main holding of Wilder is that the sale of an insurance policy is not a contract of "goods or services" under 2461(b) and 2451a(a) (definition of "consumer"). 140 Vt. at 18, 433 A.2d at 310. The Court added, however, that we were "not dealing with a contractual situation between buyer and seller" but instead being asked "to read into the Act a transaction one step removed." Id. at 19, 433 A.2d at 310.