"Pyramiding" or "stacking" as applied to an automobile insurance policy covering more than one vehicle occurs when a claimant under the provisions of a policy is permitted to aggregate the limits of the units of coverage in that policy to satisfy a claim against the insurer. This enables a maximum possible recovery of a sum equal to the declared limits of the insurer's liability multiplied by the number of vehicles covered under the policy. The Virginia Supreme Court has previously applied the concept of stacking to a claim under the medical payments coverage provision of a multi-car policy. In two recent decisions, however, the court extended the use of stacking significantly by applying the theory in settling a claim under the uninsured motorist provision for a policy insuring more than one vehicle.

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