Arizona Supreme Court

State Farm v. Balzan

July 6, 2026

Summary

The court held that multiple named insureds who jointly procure automobile insurance constitute “one insured” under the uninsured/underinsured motorist statute’s anti-stacking provision. Because Russell and Kimberly jointly purchased or procured the household policies, State Farm properly limited Connor’s recovery to his own policy and one household policy. The court vacated portions of the court of appeals’ decision and affirmed summary judgment for State Farm.