The Consumer Federation of America respectfully urges the California Supreme Court to grant the Ninth Circuit Court's request and decide both certified questions in Coleman v. United Serves Automobile Ass’n, No. 25-793 (9th Cir). As advocates for consumers, including Service Members, Veterans, and their families, we believe that these questions should be resolved in the interest of justice and marketplace fairness. We have a strong interest in this case, since we work to advance consumer interests through research, advocacy, and education. 

USAA sorts servicemembers based on their pay grade. Its underwriting guidelines assign officers and senior enlisted members in paygrades E-7 and above to United Services Automobile Association, which offers lower rates to good drivers. Essentially, it charges higher premiums to enlisted service members and unfairly discriminates against them. Almost 200,000 California policyholders are harmed by USAA’s underwriting. The good drivers who pay the higher premiums are the most junior members of the military—individuals and families that absorb the costs of relocation, deployment, and childcare on the lowest military pay.

This behavior violates California's Proposition 103 and its requirement that insurance companies sell a Good Driver Discount policy to any person who meets the statutory qualifications. We urge the California Supreme Court to take this case and decide two questions: whether USAA can give officers larger good driver discounts than enlisted members with the same record, and whether policyholders can get refunds from USAA for these violations and overcharges.