Critical Insights from the Seventh Circuit on Coverage Stacking and Insurer Liability

A recent decision by the Seventh Circuit Court provides critical insights for insurers on the policy language regarding coverage stacking. On May 28, 2026, the court ruled that Ronald and Ellen Saslow could not recover beyond the compensation already provided by Bankers Standard Insurance.

The case arose from a car accident involving Ronald Saslow and a passenger. The Saslows had both an automobile and an umbrella insurance policy with Bankers Standard. After the accident, they received $100,000 in medical expenses from their auto policy and $1 million in uninsured/underinsured motorist (UM/UIM) coverage under their umbrella policy. They also collected $879,832 from the other driver involved in the accident.

The Saslows sought further compensation, arguing they should be allowed to stack their coverage due to separate premiums for insuring five vehicles and the appearance of coverage limits twice on the policy declarations page. However, the court emphasized the anti-stacking clauses in both policies. The auto policy explicitly stated the insurer's payout would not exceed coverage limits, independent of the number of insured individuals or vehicles. Similarly, the umbrella policy restricted UM/UIM coverage to $1 million per occurrence.

The court made it clear that an anti-stacking provision does not require extensive detail to be enforceable. Listing coverage limits multiple times for logistical reasons does not introduce ambiguity. The extra declarations page was necessitated by the number of vehicles, remaining consistent with the policy’s intent.

Additional arguments by the Saslows were dismissed. They claimed coverage should extend due to involvement with a rental car, which was not underinsured, and alleged the other driver and their employer were uninsured, a claim lacking evidence.

The case also addressed claim handling delays by Bankers Standard. Under Illinois law, particularly 215 ILCS 5/155, insurers can face penalties for vexatious or unreasonable claim handling. Although payment delays exceeded the 60-day requirement after proof of loss, these were attributed to errors, not intentional delays. The court found no evidence of bad faith, thus no penalties were imposed on the insurer.