PELANDER, Justice.
¶ 1 Arizona's Uninsured/Underinsured Motorist Act (UMA), A.R.S. § 20-259.01 (2002 & Supp.2011), requires all insurers writing motor vehicle liability policies to also offer underinsured motorist (UIM) coverage that "extends to and covers all persons insured under the policy." § 20-259.01(B). UIM coverage applies when an insured's total damages exceed all applicable liability limits, subject to any valid limitations the insurer imposes. See § 20-259.01(G)-(H). But any "exceptions to [UIM] coverage not permitted by the [UMA] are void." Taylor v. Travelers Indem. Co., 198 Ariz. 310, 315 ¶ 13, 9 P.3d 1049, 1054 (2000); see also Cundiff v. State Farm Mut. Auto. Ins. Co., 217 Ariz. 358, 360 ¶ 9, 174 P.3d 270, 272 (2008).
¶ 2 In the underlying federal court action, the insurer, American Family Mutual Insurance Company, sought a declaratory judgment that it had validly denied an insured's UIM claim. The insured, Sabine Sharp, counterclaimed for breach of contract and bad faith. The United States District Court for the District of Arizona certified three questions to this Court:
¶ 3 We accepted jurisdiction pursuant to Article 6, Section 5(6) of the Arizona Constitution, A.R.S. §§ 12-1861 to -1867 (2003), and Arizona Supreme Court Rule 27. We answer the first question in the affirmative and the second in the negative, and therefore find it unnecessary to answer the third.
¶ 4 The District Court's certification order stated the relevant facts as follows:
¶ 5 The Escape Policy's UIM endorsement has an "Other Insurance" clause that states: "If two or more policies are issued to you by us or any other member company of the American Family Insurance Group of companies, apply [sic] to the same accident, only one of the policies will apply. You will select the one policy that will apply." The Motorcycle and Escape Policies both define "you" as "the policyholder shown in the Declarations and spouse, if living in the same household."
¶ 6 The first two certified questions turn on the interplay between Subsections (G) and (H) of § 20-259.01. Subsection (G) states:
¶ 7 Subsection (H) provides:
(Emphasis added.)
¶ 8 After receiving payment of the bodily injury liability limit under the Motorcycle Policy, Sabine Sharp did not claim UIM coverage under that policy, but rather only under the separate Escape Policy. American Family argues that it properly denied that claim because, under Subsection (H), it may "preclude an insured from stacking coverages under multiple insurance policies," even when the coverage types differ.
¶ 9 Sharp, however, contends that Subsection (G) entitles her "to fill the gap between her actual damages and the available liability recovery with the UIM coverage that she purchased separately for this purpose." Subsection (H), Sharp argues, only "permits insurers to prevent stacking of those first-party coverages (UM or UIM) addressed by § 20-259.01, where one insured has purchased the same first-party coverage on multiple vehicles from one insurer, either in a single policy, or multiple policies." Noting that she "is not attempting to `stack' multiple UIM coverages," Sharp contends Subsection (H) does not apply when, as here, "two different coverages, under two different policies, purchased by two different individuals, [apply] to one loss." To the extent American Family's "Other Insurance" clause would preclude her UIM claim under the Escape Policy, Sharp argues, it violates the UMA.
¶ 10 The UMA's text alone does not resolve the parties' dispute. We must therefore
¶ 11 This Court has previously found that "the legislature intended a broad application of UIM coverage to provide benefits up to the policy limits whenever the insured is not indemnified fully by the available limits of liability." Taylor, 198 Ariz. at 315 ¶ 15, 9 P.3d at 1054. Similarly, we have said that Subsection (G) "explicitly entitles an insured to UIM coverage if the sum of the limits of all applicable liability policies is less than the total damages resulting from the accident." Id. at ¶ 14.
¶ 12 Subsection (H) is the only UMA provision that authorizes any limitation of UM or UIM coverage. That subsection's first two sentences provide that those coverages "are separate and distinct," and that UIM coverage, either in one or several policies, cannot be applied to a claim against an uninsured motorist. The anti-stacking provision in Subsection (H)'s third sentence permits an insurer to limit "the coverage" to "only one policy or coverage" when "multiple policies or coverages purchased by one insured on different vehicles apply to an accident or claim." § 20-259.01(H).
¶ 13 American Family urges us to read "multiple policies or coverages" and "one policy or coverage" to mean all available coverages, regardless of type. But under that reading, an insurer could limit an insured's recovery for all accident-related damages to only one type of selected coverage, whether it be for medical payments, rental car reimbursement, property damage (under the collision coverage), liability, or UIM, regardless of the number of policies issued, coverages purchased, premiums paid, or vehicles covered. We find no indication in Subsection (H) or elsewhere that the legislature intended that result, particularly in light of the UMA's broad remedial purpose.
¶ 14 In addition, statutory terms must be construed in context. See Adams v. Comm'n on Appellate Court Appointments, 227 Ariz. 128, 135 ¶ 34, 254 P.3d 367, 374 (2011). The only types of coverage addressed in the UMA, including Subsection (H), are UM and UIM.
¶ 15 The most reasonable interpretation of Subsection (H) is that the phrase "multiple policies or coverages" applies when an insured obtains coverages for several vehicles and then attempts to claim multiple UIM coverages for the same accident. Cf. Rashid v. State Farm Mut. Auto. Ins. Co., 163 Ariz. 270, 272 n. 2, 787 P.2d 1066, 1068 n. 2 (1990) (noting that under the UMA, stacking may be prohibited "when an insured has purchased multiple coverages from one insurer against the same event and seeks to stack the limits provided by any single coverage"). Subsection (H) authorizes an insurer in that situation to "limit the coverage so that only one policy or coverage, selected by the insured, shall be applicable to any one accident," thereby confining the insured to only one UIM policy or coverage. See Taylor, 198 Ariz. at 320 ¶ 28, 9 P.3d at 1059 (noting that Subsection (H) "allows the preclusion of stacking UIM coverages from separate policies purchased by the insured from the same insurer").
¶ 16 Subsection (H), however, does not permit an insurer to deny UIM coverage under a policy merely because the insured was partially indemnified as a claimant under the liability coverage of a different policy
¶ 17 These conclusions comport not only with the terms of the UMA and its overarching purpose, but also with our case law. Although no prior decision directly controls the issue presented here, we have repeatedly recognized that liability insurance is distinct from first-party UIM coverage. Taylor, 198 Ariz. at 316 ¶ 16, 9 P.3d at 1055; State Farm Mut. Auto. Ins. Co. v. Wilson, 162 Ariz. 251, 258, 782 P.2d 727, 734 (1989). "[T]he purpose of UM and UIM coverage is to enable the consumer to protect himself and family members against the possibility that, in any given accident, there will be no or insufficient liability coverage to compensate for the actual damages sustained." Taylor, 198 Ariz. at 316 ¶ 18, 9 P.3d at 1055. An insured who purchased coverage against two separate risks, each of which occurred, generally may recover under both coverages. Id. at ¶ 16.
¶ 18 The UMA has "a remedial purpose and must be construed liberally in favor of coverage, with strict and narrow construction given to offsets and exclusions." Id. at 314 ¶ 11, 9 P.3d at 1053. Although "[i]nsurers justifiably include other insurance clauses to prevent the insured from duplicating recovery," most courts have found that "insurers violate the public policy embodied in the UM/UIM statutes by inserting clauses that permit them to reduce or eliminate coverage when the victim/insured has not been fully compensated." Brown v. State Farm Mut. Auto. Ins. Co., 163 Ariz. 323, 328, 788 P.2d 56, 61 (1989); cf. Rashid, 163 Ariz. at 273, 787 P.2d at 1069 ("`A premium has been paid for each of the coverages.... It seems both equitable and desirable to permit recovery under more than one coverage until the claimant is fully indemnified.'" (quoting 1 A. Widiss, Uninsured and Underinsured Motorist Insurance § 13.6, Comment at 403-04 (2d ed. 1987))). American Family's proffered interpretation of Subsection (H) clashes with these established principles.
¶ 19 Contrary to American Family's argument, neither Taylor nor Lindsey supports a contrary conclusion. Taylor held that an insured was "covered up to the face amount of the applicable UIM insurance, less any sums recovered under the liability coverage of the same policy," in order "to fill the gap between the amount she received from all applicable liability coverages and her UIM coverage limits." 198 Ariz. at 312 ¶ 1, 321 ¶ 32, 9 P.3d at 1051, 1060. Unlike this case, Taylor involved an insured who sought both liability and UIM coverage under a policy that covered a single vehicle. Id. at ¶ 2. Here, in contrast, Sharp seeks UIM coverage under her Escape Policy, but received the liability payment under the separate Motorcycle Policy.
¶ 21 Lindsey also does not help American Family. That case held that, although Subsection (H) generally authorizes insurers to prevent "stacking ... [of] the same coverage under two or more policies," the carrier there "did not take the steps necessary to effectuate the limitation" authorized by that statute. 182 Ariz. at 331, 332, 897 P.2d at 633, 634. Because the policies were deficient in that regard, Lindsey did not address whether the anti-stacking provision applies to all types of coverages, or rather only like-kind UIM coverages.
¶ 22 In sum, neither Taylor nor Lindsey addressed whether Subsection (H) permits an insurer to preclude recovery of UIM benefits under a second policy (covering a separate, non-accident vehicle), based on the insured's recovery under the liability coverage of a different policy covering the accident vehicle. Sharp's UIM claim is protected by the broad coverage requirement of Subsection (G), and it is not limited by Subsection (H)'s anti-stacking provision.
¶ 23 For the reasons above, we answer the first certified question in the affirmative and the second in the negative, and find it unnecessary to answer the third.
CONCURRING: REBECCA WHITE BERCH, Chief Justice, ANDREW D. HURWITZ, Vice Chief Justice, W. SCOTT BALES and ROBERT M. BRUTINEL, Justices.