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In Kaiama v. AIG Hawaii, Inc., 84 Haw. 133, 930 P.2d 1352 (1997) the Hawaii Supreme Court refused to enforce a "family member" UIM insurance exclusion in a auto insurance policy issued by AIG. The exclusion purported to deny UIM coverage to an insured family member injured by another insured under the same policy - apparently for the purpose of denying dual recovery under both the liability and the UIM coverages of the same insurance policy. The Hawaii Supreme Court stated that an insurer's use of the family member exclusion to deny UIM coverage to an insured who has liability coverage for the same injury caused by a family member violates public policy and is therefore void. Dual recovery of both liability and UIM coverages to an insured family member was therefore permitted.
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