Kenneth W. Dodge and Louise A. Behrendt obtained a favorable ruling from the Minnesota Supreme Court on behalf of Allstate Insurance Company in a case where the court established that an insured cannot use the doctrine of “reasonable expectation” to obtain coverage when the policy unambiguously precludes it. See Carlson v. Allstate Ins. Co., 749 N.W. 2d 41 (Minn. 2008). In that case the plaintiffs, a father and son, sought underinsured coverage from Allstate after the son, covered under his father’s Allstate auto policy as a “driver,” was injured as a pedestrian, while crossing the street. The court first found that the policy unambiguously precluded UM coverage for the son under these circumstances, and went on to address the doctrine of reasonable expectations, which it first discussed in Atwater Creamery Co. v. Western Nat’l Mut. Ins. Co., 366 N.W. 2d 271 (Minn. 1985). While the court in Atwater left open the possibility than an insured’s reasonable expectations could be honored even in the absence of policy ambiguity, the court in Carlson clarified that the doctrine should not be expanded beyond its current use as a tool for resolving ambiguity and for correcting the kind of extreme situation that existed in Atwater.