Judge Mannion of Federal Middle District Court Tackles Sackett Rejection of Stacking Analysis

In his recent memorandum decision in the case of Mitchell v. Progressive Pref. Ins. Co., No. 3:14-0384 (M.D.Pa. Sept. 29, 2015 Mannion, J.), Judge Malachy E. Mannion  granted summary judgment in favor of the Defendant carrier on a stacking issue after a review of the Sackett line of cases.

As the Sackett analysis can be convoluted, a link to the decision is provided below for review.

Judge Malachy E. Mannion
Federal Middle District Court

Ultimately, the court ruled that the carrier was not required to obtain a new rejection of stacking issue when the Plaintiff added a vehicle (motorcycle) to the policy.  Judge Mannion based his decision upon the application of the continuous "after-acquired" clause contained in the policy.

Anyone wishing to review this decision in detail may click this LINK

I send thanks to Attorney David Friedman of the King of Prussia law office of Forry Ullman for bringing this case to my attention.