In Olson v. Wisconsin Mutual Insurance Co. (2017AP1567), the Court of Appeals District III held that a request for “full coverage” did not make an insurance agent negligent for failing to include off-property automobile coverage in a homeowner’s policy, nor did it make the policy eligible for reformation.

Jeffrey Keyes had automobile insurance through Wisconsin Mutual Insurance Co. He also had a farmowners policy from Rural Mutual Insurance Co. with attached umbrella liability coverage. The umbrella coverage specifically excluded coverage for occurrences related to the use of automobiles away from the covered property. When Keyes was involved in an accident on a public road, he sought coverage from Rural under the umbrella policy, and Rural denied coverage based on the off-property exclusion.

On appeal, Keyes sought reformation of his Rural policy because he claimed there was a “mutual mistake” in that the policy was issued with the off-property exclusion. Keyes contended that his request for “full coverage” meant his insurance agent should have included off-property occurrences in the policy and suggested his agent was negligent in implementing the off-property exclusion in the policy. Because Keyes never specifically asked for off-property coverage, the court denied his claim for policy reformation and his claim of agent negligence, citing precedent that generic requests for coverage do not trigger an obligation for agents to include coverage for specific risks in a policy.

The court also denied Keyes’s argument that his satisfying of the policy’s underlying insurance requirement through a separate insurer should have made him eligible for off-property umbrella coverage.