Erroneous execution of “Connecticut Consent Form” for election of uninsured motorist coverage does not bind insurer if insured proves intent to reject coverage.

The District Court held that, even though Ryder Systems, Inc. mistakenly signed a consent form without excluding $1 million in underinsured motorist coverage, this was not binding when extrinsic evidence proved Ryder intended to only provide basic $25,000/$50,000 coverage limits. The court disagreed with the plaintiff’s argument that execution of the consent form unambiguously demonstrated Ryder’s intent, when its risk manager had soon thereafter signed a corrected disclosure form, which Ryder and ACE argued reflected Ryder’s intent at the inception of the policy. 

This opinion relies on an accepted rules that: (1) “[S]trict adherence” to informed consent requirements under Connecticut law is unnecessary to reduce coverage limits; and (2) commercial fleets are not burdened with protection of their own injured employees or the financial risk that a third-party will not carry adequate insurance. Therefore, Ryder and ACE Chubb were able to effectively limit their coverage and liability exposure by showing the coverage the parties intended to provide.
 

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