An antique-car policy doesn't have to repeat uninsured motorist coverage the driver already carries elsewhere, a federal appeals court ruled.
The Eleventh Circuit reversed a lower court on July 8, 2026, siding with Essentia Insurance Company in an Alabama coverage dispute. It's a useful marker for any carrier writing specialty or adjunctive auto policies.
Here's what happened. The driver was hurt by an uninsured motorist while riding his motorcycle. He owned two vehicles that mattered here: the motorcycle and an antique 1965 Ford F-100. He also held two policies. GEICO covered the motorcycle under a standard auto policy costing $197.52 a year. Essentia covered the antique Ford under a specialty policy at $117 a year.
He collected $25,000 in uninsured motorist benefits from GEICO - the full amount Alabama law requires. Because he wasn't in or on the Ford when the crash happened, Essentia's policy added nothing. He filed a claim with Essentia anyway, arguing Alabama law required the specialty policy to carry its own portable coverage. Essentia said no. He sued.
The policy wording did most of the work. Essentia's Classic Automobile Policy defined an "insured" for uninsured motorist purposes narrowly - covering people only "while using or occupying [the] covered auto" or "while not occupying a motor vehicle." It stated that "insured shall NOT mean and does NOT include" people hurt while using vehicles other than the covered antique.
The key catch: the specialty policy required the driver to keep a separate policy that "[s]atisfies all minimum state insurance requirements, including but not limited to minimum requirements for liability coverage, uninsured motorist coverage and underinsured motorist coverage." He did. GEICO paid.
The district court sided with the driver on liability but capped Essentia's exposure at Alabama's $25,000 minimum, entering judgment against the insurer for that amount. Essentia appealed.
The appeals court reversed. Because the Alabama Supreme Court hasn't decided the question, the panel predicted how it would rule. It pointed to Alabama Code § 32-7-22(j), which says the requirements for a motor vehicle liability policy "may be fulfilled by the policies of one or more insurance carriers." In short: mandatory uninsured motorist coverage can be spread across more than one policy.
The court also noted that other states have reached the same result on near-identical facts, and made a practical point: specialty antique-car policies charge lower premiums because the cars see limited use, so forcing duplicate coverage would push premiums up.
For claims professionals, the reasoning is the takeaway. Quoting Alabama precedent, the panel wrote that "[t]he law is only concerned that required coverage is provided, not by what or which carrier." Essentia's policy, it added, "does not deny uninsured motorist coverage in this case - it simply allocates the required coverage to the insured's standard policy."
The matter was reversed and remanded.
