3rd District Court of Appeals Decision: Renstrom v. Progressive (Injury Coverage)

In Renstrom v. Progressive Preferred Insurance, Co. (2017AP859), the Court of Appeals District III held that the plaintiff’s injuries were not covered because the Progressive policy did not list the location at which they occurred as a scheduled premise.

Plaintiff Rolayne Renstrom was injured in an accident with a wood splitter on a cabin property owned by Pauline Reagor. The cabin property was insured by Little Black Mutual Insurance Company. Reagor also had a policy with Progressive that listed only her condominium in Stillwater, Minnesota as a covered scheduled premise. After the accident Renstrom filed the present suit against Progressive seeking coverage for her injuries.

Despite Renstrom’s arguments that the policy’s language was ambiguous, the court upheld that her injuries were not covered because the cabin property was not listed as a scheduled premise under the Progressive policy. Furthermore, the court maintained that Renstrom’s injuries did arise from Reagor’s ownership of the cabin property because, among other reasons, they were splitting wood to use for the cabin’s stove when the injury occurred. The causal connection between the injury and the unscheduled cabin property means Progressive was not required to cover the injury.