Louisiana Supreme Court Affirms Anti-Stacking UM Law in Lanclos v. State Farm 

The Louisiana Supreme Court has denied writs in Lanclos v. State Farm Mutual Insurance Company. This decision solidified a key appellate victory for Leake Andersson and reaffirmed Louisiana’s long-standing anti-stacking uninsured/underinsured motorist (UM/UIM) law. 

Last fall, the Leake Andersson team of Jason Bonnett, Dean Arruebarrena, and Leila D’Aquin secured a decisive win in the Louisiana Third Circuit Court of Appeal in Lanclos v. State Farm Mut. Ins. Co., 2025-129 (La. App. 3 Cir. 9/17/25), 420 So.3d 311. 

Case Background 

The plaintiff was injured in an automobile accident caused by an underinsured driver while driving her personal vehicle on a job-related trip. She accepted and collected the full policy limits under her own UM policy. Later, she filed suit against her employer’s UM carrier, seeking to recover additional UM benefits under that policy. 

The employer’s UM carrier, represented by Leake Andersson, moved for summary judgment. Our team argued that Louisiana’s anti-stacking statute bars recovery of multiple UM benefits under these circumstances. The Court of Appeal affirmed the trial court’s grant of summary judgment in favor of our client.  

Louisiana Supreme Court Denial of Writs 

Following the Court of Appeal’s ruling, the plaintiff sought a writ from the Louisiana Supreme Court. The plaintiff suggested that years after collecting under one policy, she should be able to rescind that acceptance and pursue recovery from a different insurer.

Leake Andersson’s appellate team opposed the application. In a 6-1 denial of the application last week, the Supreme Court solidified the state’s policy. A person who is injured while driving their own vehicle and collects under their own UM coverage cannot go on to collect additional UM benefit under her employer’s policy. Lanclos v. State Farm Mut. Ins. Co., 2025-01314 (La. 1/21/26), 424 So. 3d 1098. 

Why This Decision Matters 

The Supreme Court’s action confirms a clear and consistent rule under Louisiana law: an individual injured while driving her own vehicle who collects UM benefits under her personal policy may not later seek additional UM recovery under an employer’s policy. 

This ruling provides important clarity and predictability for insurers, employers, and practitioners navigating UM/UIM coverage disputes in Louisiana.