Pennsylvania Federal Court Rules that Insurance Information Is Not Admissible at Post-Koken Trial on UIM Claims

In the case of Saeli v. Geico Adv. Ins. Co., No. 1:24-CV-00025-RAL (W.D. Pa. Jan. 28, 2026 Lanzillo, Chief Mag. J.), the Chief Magistrate Judge for the Western District Federal Court of Pennsylvania addressed a Motion In Limine filed a UIM carrier in a post-Koken case seeking to preclude the Plaintiff from introducing any evidence or testimony regarding the amount of the tortfeasor’s liability limits, the UIM limits, or any premiums paid.

The court ruled that, since the probative value of such evidence, if any, is substantially outweighed by the danger of unfair prejudice and confusion on the issues presented, the UIM carrier’s Motion was granted.

The court additionally found that the evidence at issue is irrelevant to the issues presented in the trial. The court noted that the central issue in the case was the extent of the damages sustained by the Plaintiff. As such, the court found that the amount of the tortfeasor’s liability limits, the UIM limits, and the premiums paid were irrelevant to such issues.

The court noted that, while the tortfeasor’s liability coverage will have to be credited to the UIM carrier, the court noted that this is a simple mathematical calculation that the court could accomplish by molding the verdict after the verdict is handed down the jury and without the need to involve the jury.

The court felt that requesting a jury to apply the liability limit against the UIM benefits coverage would unnecessarily complicate the issues before the jury and could risk prejudice to Geico.

Magistrate Judge Lanzillo included in his Opinion a review of other Pennsylvania federal court decisions on the issue and noted that all but one had held the evidence of coverage limits and premiums paid provided no benefit to the jury in determining the issue of damages in post-Koken cases and that, even if such evidence was minimally relevant, its probative value was substantially outweighed by the risk of unfair prejudice to the Defendant. See Op. at 4.

It is noted that the court additionally indicated that the Plaintiff did not file a Response to Geico’s Motion In Limine by the time of the deadline set by the court.

Anyone wishing to review a copy of this decision may click this LINK.

I send thanks to Attorney Joseph Hudock of the Pittsburgh office of the Summers, McDonnell, Hudock, Guthrie & Rauch, P.C. law firm for bringing this case decision to my attention.


Please note that the Post-Koken scorecard on the Tort Talk blog will be updated with this decision.

The post-Koken scorecard on the Tort Talk blog is always freely available for research. You can access the scorecard by going to www.TortTalk.coom and scrolling a bit down the hand column to the label for Post-Koken Scorecard and clicking on the date under that.

Source of image:  Photo by Scott Greer on www. unsplash.com.