intent.”). To make matters worse, we have not required an actual duplication of benefits when an owned-but-not-insured exclusion is contained in underinsured motorists (UIM) coverage. We have said that, in the context of UIM coverage, there is “no duplication of benefits until the victim has been fully compensated.” McClure v. Northland Ins. Co., 424 N.W.2d 448, 450 (Iowa 1988) (applying section 516A.2(1)’s duplieation-of-benefits provision). Yet in Kluiter v. State Farm Mutual Automobile Insurance Co., 417 N.W.2d 74 (Iowa 1987), we upheld an owned-but-not-insured exclusion with no discussion of whether the insured had been fully compensated for his injuries. 417 N.W.2d at 76. Instead, we merely found “potential duplication.” Id.(emphasis added); see also Hornick, 511 N.W.2d at 374 (<HOLDING>). Our inconsistent application of the statute’s
holding that prospective buyer of used car could not recover under dealers uim endorsement because uim insurance is not for protection of vehicles but of persons holding that insurers failure to deny existence of insurance coverage under policy at issue was to admit that coverage existed holding the uim policy provision at issue may be viewed as an attempt to avoid duplication of insurance coverage and is therefore permitted under iowa code section 516a2 emphasis added holding that the plain meaning of the uim policy language was clear and not contrary to public policy holding plaintiffs uim claims did not accrue until his lawsuit against the underinsured driver was resolved where insurance policy provided for uim coverage only after liability policies had been exhausted