Case Citator › Scott-Pontzer v. Liberty Mutual Fire Insurance

Scott-Pontzer v. Liberty Mutual Fire Insurance

Is it still good law? What later courts have actually done to this case.

Superseded by statute
Court
Supreme Court of Ohio
Citation
85 Ohio St. 3d 660
Decided
Confirmed treatments
3
Flagged citations read
108 of 108
Citing cases (total)
963
Treatment dates
2002–2003
Superseded by statute
A reviewed court treats this case as superseded by later legislation. Scott-Pontzer v. Liberty Mutual Fire Insurance has been superseded by statute: all 108 flagged citations have been read, and the 3 confirmed treatments are listed below. The Supreme Court of Ohio recognized that 2001 amendments to Ohio's uninsured-motorist statute expressly superseded Scott-Pontzer and separately limited its rule to employees acting within the course and scope of employment.
More on how this was screened

The First Circuit declined to follow its policy construction under Maine law. The other reviewed opinions applied those decisions, distinguished different policy text, or used “overruled” as loose history shorthand for Galatis's narrower limiting act.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

963 later cases cite Scott-Pontzer v. Liberty Mutual Fire Insurance; 108 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Scott-Pontzer v. Liberty Mutual Fire Insurance?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Superseded by Statute

  • The Supreme Court of Ohio recognized that the General Assembly's 2001 amendments to Ohio's uninsured-motorist statute expressly superseded Scott-Pontzer.

    Westfield Insurance Co. v. Galatis · Supreme Court of Ohio · filed

    The General Assembly has enacted changes to R.C. 3937.18 expressly to supersede Scott-Pontzer. Section 3, 2001 Am.Sub.S.B. No. 97 (eff. Oct. 31, 2001).
    Read the full opinion on CourtListener →

Limited

  • The Supreme Court of Ohio limited Scott-Pontzer's extension of corporate uninsured-motorist coverage to off-duty employees, retaining it only for losses within the course and scope of employment absent contrary policy language.

    Westfield Insurance Co. v. Galatis · Supreme Court of Ohio · filed

    For the foregoing reasons, we hereby limit Scott-Pontzer v. Liberty Mut. Fire Ins. Co. to apply only where an employee is within the course and scope of employment. We overrule Ezawa v. Yasuda Fire & Marine Ins. Co. of Am.
    Read the full opinion on CourtListener →

Declined to Follow

  • The First Circuit declined to follow Scott-Pontzer's conclusion that “you” in a corporate uninsured-motorist endorsement was ambiguous, calling that reading anomalous under Maine contract law.

    Seaco Insurance Co. v. Davis-Irish · First Circuit · filed

    We consider Scott-Pontzer an anomaly and we therefore decline to follow it.
    Read the full opinion on CourtListener →

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