Nationwide Mutual Insurance v. Stokes
Mary Stokes was injured in a car accident caused by Russell Caldwell and Steven Schwartz. She settled with their insurer, Aetna Insurance Company, for the policy limit of $10,000. Stokes then sought underinsured motorist benefits from her own insurer, Nationwide Mutual Insurance Company, which provided $50,000 in coverage. Nationwide argued it was entitled to offset the $10,000 settlement and $2,100 in Workers’ Compensation benefits from Stokes's coverage. The Supreme Court initially allowed both offsets, limiting Stokes's recovery to $37,900. On appeal, the court ruled that the $10,000 tortfeasor settlement could not be offset against the underinsurance limits, but the Workers’ Compensation benefits could. Therefore, the order was modified to remove the $10,000 offset but affirmed regarding the Workers’ Compensation offset.