On July 6, 2026, the Arizona Supreme Court held that multiple individuals who jointly purchase multiple insurance policies from the same insurer constitute “one insured” for the purposes of the anti-stacking provisions of A.R.S. § 20-259.01(H). Thus, an insurance company may prohibit a claimant from stacking multiple policies jointly purchased by multiple individuals from the same insurer.

Arizona’s Uninsured/Underinsured Motorist Act (“UM / UIM”) allows an individual covered by more than one automobile insurance policy to collect benefits from multiple policies, i.e. “stack” the UM / UIM benefits unless the insurer strictly complies with the terms of A.R.S. § 20-259.01(H).[1] In 2023, the Arizona Supreme Court held that insurers seeking to prevent the stacking of UIM coverages under a single multi-vehicle insurance policy can only do so by following the terms of A.R.S. § 20-259.01(H). Franklin v. CSAA General Insurance Co.,255 Ariz. 409 (2023).  More recently, however, a claimant attempted to stack UIM benefits across multiple insurance policies issued to multiple insured individuals who jointly purchased the policies. State Farm Mutual Automobile v. Balzan, CV-24-0140-PR (Ariz. July 6, 2026).

The plaintiff, Connor Balzan, argued that multiple insured individuals do not constitute “one insured” under the statute, A.R.S. § 20-259.01(H), in his attempt to stack the benefits of multiple policies. Arizona’s Supreme Court rejected that argument and held that joint purchasers of multiple policies from the same insurer constitute “one insured” under the statute.

Mr. Balzan was injured in an automobile accident on April 5, 2019, and sustained injuries leading to medical expenses that exceeded the responsible party’s insurance coverage. Mr. Balzan thereafter sought UIM benefits from his insurer, State Farm. Mr. Balzan argued that he was entitled to the UIM benefits of his own policy as well as the stacked benefits of four policies purchased by his parents because he was part of their household at the time of the underlying collision.

State Farm paid Mr. Balzan the UIM benefits of his own policy and one of his parents’ policies, in line with A.R.S. § 20-259.01(H). Despite this, Mr. Balzan argued that he was entitled to the benefits of the three additional policies because each individual who contributed to paying the policy premium constituted a separate purchaser and, therefore, a separate insured. Interestingly, the trial court, Arizona Court of Appeals, and Supreme Court all rejected this position, albeit for somewhat different reasons. Balzan, ¶¶ 5–7.

Ultimately, the Supreme Court rejected Mr. Balzan’s argument because it would undermine the statute’s language and “leave insurers unable to determine the scope of subsection (H) from the policy itself.” Balzan, ¶ 19. Instead, the Supreme Court held that all named insureds on a policy constitute “one insured” for the purposes of the anti-stacking provisions of § 20-259.01(H). Thus, insurers can continue to limit stacking according to the terms of that subsection, even in cases of multiple individuals who jointly purchase a policy, such as a married couple.

Read the entire opinion here.

[1] The full text of subsection (H) reads: “Uninsured and underinsured motorist coverages are separate and distinct and apply to different accident situations. Underinsured motorist coverage shall not provide coverage for a claim against an uninsured motorist in addition to any applicable uninsured motorist coverage. If multiple policies or coverages purchased by one insured on different vehicles apply to an accident or claim, the insurer may limit the coverage so that only one policy or coverage, selected by the insured, shall be applicable to any one accident. If the policy does not contain a statement that informs the insured of the insured’s right to select one policy or coverage as required by this subsection, within thirty days after the insurer receives notice of an accident, the insurer shall notify the insured in writing of the insured’s right to select one policy or coverage. For the purposes of this subsection, “insurer” includes every insurer within a group of insurers under a common management.”

About Christian, Dichter & Sluga

Christian, Dichter & Sluga is a nationally recognized insurance and litigation law firm providing sophisticated legal solutions throughout Arizona, Nevada, and New Mexico. For nearly 50 years, our attorneys have represented insurers, businesses, and organizations in complex coverage disputes, bad faith matters, litigation, and aviation-related claims. What sets CDS apart is the combination of deep courtroom experience, peer-recognized legal talent, and a collaborative approach that delivers the resources of a larger firm with the responsiveness and personal attention clients value. We don’t just know the law – we know the communities, courts, and industries we serve, allowing us to provide strategic counsel and outstanding results when our clients need it most.

The purpose of this publication is to provide readers with information on current topics of general interest and nothing herein shall be construed to create, offer, or memorialize the existence of an attorney-client relationship. The content should not be considered legal advice or opinion, because it may not apply to the specific facts of a particular matter. As guidance in areas is constantly changing and evolving, you should consider checking for updated guidance, or consult with legal counsel, before making any decisions.

This admission marks another significant milestone in Madison’s legal career and further expands her ability to advocate for clients in both state and federal court. It also reflects the dedication, professionalism, and passion for advocacy that have defined her career from the very beginning.

Madison’s commitment to the legal profession began during high school through mock trial competitions, where she discovered her passion for courtroom advocacy and criminal defense. She continued to develop those skills at Michigan State University, earning a degree in Political Theory and Constitutional Democracy through the James Madison Honors College while distinguishing herself as an accomplished mock trial and moot court competitor. During her undergraduate career, she founded the MSU Undergraduate Moot Court Association and earned numerous individual advocacy awards.

She later attended the Sandra Day O’Connor College of Law at Arizona State University, where she built an impressive record of success in trial advocacy and oral argument competitions. While participating in Arizona’s Rule 39 program, Madison gained valuable courtroom experience by assisting with DUI trials, conducting evidentiary hearings, and representing real clients under the supervision of licensed attorneys. Her dedication to advocacy earned her numerous honors, including the Janet S. Muller Oral Advocacy Award, Order of the Barristers, Best Overall Advocate at the National Trial Advocacy Competition, and multiple first-place finishes in prestigious advocacy competitions.

Today, Madison brings that same passion, preparation, and commitment to every client she represents at Christian, Dichter & Sluga. In addition to serving clients, she continues to give back to the legal community by coaching Sun Devil Mock Trial, mentoring the next generation of trial advocates.

Madison’s admission to the United States District Court for the District of Arizona is a testament to her continued professional growth and unwavering commitment to excellence in the practice of law. We are proud to celebrate this achievement and look forward to her continued success as she serves our clients and our community.

Please join us in congratulating Madison on this well-deserved accomplishment.