Mid-Century Insurance Co. of Texas v. Kidd
This case addresses whether an insured can recover the same loss under both uninsured/underinsured motorist (UM/UIM) and personal injury protection (PIP) coverages of a standard automobile insurance policy in Texas. The Supreme Court consolidated two cases, Kidd and Gerlich, where lower courts refused to enforce a policy provision barring duplication of UM and PIP benefits. The Court held that a non-duplication-of-PIP-benefits provision is valid and enforceable, reversing the judgments of the courts of appeals. The decision clarifies that this offset provision prevents double recoveries, rather than reducing UM/UIM policy limits or causing insureds to recover less than actual damages, and is consistent with Texas statutes and common law.