In Mid-Century Insurance v. Werley, 2024 U.S. App. LEXIS 22554, 114 F.4th 200 (U.S. Ct. of App., 3d Cir., September 5, 2024) (Rendell, J.), the U.S. Court of Appeals for the Third Circuit waded into the muddy waters of Pennsylvania's precedents on stacking and the household exclusion. It examined the fact situation before it and determined that the household exclusion at issue must be enforced in order to be consistent with current Pennsylvania Supreme Court precedents. In doing so, the Circuit Court also demonstrated that precision in language matters.

Levi Werley was seriously injured while riding an uninsured motorized dirt bike. When the insurance of the driver that struck him did not compensate him fully for his injuries, Levi's parents, Chad and Jane Werley, sought to recover underinsured motorist (UIM) benefits under their own automobile insurance policies. The Werleys' insurer, Mid-Century Insurance Co. (Mid-Century), paid out $250,000 under one policy. But the Werleys maintain that they are entitled to an additional $250,000 under another household policy. In their view, that policy's household vehicle exclusion, which bars payments for bodily injury sustained while occupying an uninsured vehicle, is invalid and unenforceable.