A federal appeals court just handed insurers a clean win on stacking – and a reminder that broad policy wording beats long factor-by-factor lists.
In a decision issued May 28, 2026, the Seventh Circuit ruled that Ronald and Ellen Saslow could not recover more than the limits Bankers Standard Insurance had already paid on their claims.
Ronald Saslow and a passenger were hurt in a car accident. The Saslows carried both an auto policy and an umbrella policy with Bankers Standard and filed claims. The company paid $100,000 for medical expenses under the auto policy and $1 million in uninsured/underinsured motorist (UM/UIM) coverage under the umbrella policy. The couple had also collected $879,832 from the other driver.
They wanted more. The Saslows argued they could stack their coverage – recover the limits more than once – because they paid separate premiums on each of their five vehicles, the limits appeared twice on the declarations page, and more than one person was insured.
The court said no, for reasons that matter to anyone drafting policy language. Both policies carried anti-stacking wording. The auto policy said the company would pay up to the coverage limit, and that this was the most it would pay regardless of how many people or vehicles were involved. Its other insurance clause sealed it: a recovery could equal, but not exceed, the highest applicable limit for any one vehicle under that policy or any other. The umbrella policy set a $1 million UM/UIM limit per occurrence, the most payable no matter how many insured people, claims, injuries, locations, or vehicles were involved.
An anti-stacking clause, the court said, doesn't have to spell out every factor to work. And listing the limits twice didn't create ambiguity – the second page existed only because five cars wouldn't fit on one.
Two fallback arguments also failed. A rental car didn't trigger extra coverage, because the other vehicle wasn't underinsured. And a claim that the other driver and his employer were both uninsured was waived for lack of evidence.
The closest call was on delay. Illinois law, under 215 ILCS 5/155, lets courts award fees when an insurer's claim handling is vexatious and unreasonable. Bankers Standard owed payment within 60 days of proof of loss and came up two months late, with the Saslows' attorney sending at least six written demands over four months. But the company kept trying to pay and repeatedly had to issue new checks. The court called it a mistake, not bad faith, and found no evidence the insurer meant to drag its feet. Delay alone wasn't enough.
