Keane v. Auto-Owners Ins. Co

In Keane v. Auto-Owners Ins. Co., 159 Wis. 2d 539, 551-53, 464 N.W.2d 830 (1991), a Wisconsin driver was killed in an accident with a driver carrying automobile insurance issued in Michigan. 159 Wis. 2d at 541-42. The Michigan driver's insurance had a $ 20,000 bodily injury liability limit and the Keanes argued that they were entitled to uninsured motorist coverage because their policy defined an uninsured vehicle as one with a bodily injury liability limit of less than the $ 25,000 required by Wisconsin's financial responsibility laws. See id. However, the Michigan driver's policy also contained an extraterritorial clause stating that the bodily injury liability insurance provided "shall comply with the provisions of the motor vehicle financial responsibility law of any state or province to the extent of the coverage and limits of liability required by such law." 159 Wis. 2d at 542-43. The supreme court concluded that this clause increased the Michigan driver's liability limit to the amount required by Wisconsin's financial responsibility laws and, therefore, he was not uninsured. See id. at 543.